Management and Oversight of 

Interagency Acquisition Agreements

at the SEC 

 

 

March 26, 2010 

Report No. 460 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page i 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20J549

O ....'CIE 0 ..

'N.PIECTOR GEN .......L

MEMORANDUM

March 26. 2010

To: Sharon Sheehan, Office of Administrative Services (OAS)

Associate Executive Director

Kenneth Johnson, Office of Financial Management (OFM), Acting

Associate Executive Director

Jeffrey A. Risinger, Office of Human Resources (OHR), Associate

Executive Director

From: H. David Kotz, Inspector General, Office of Inspector General (OI

Subject: Management & Oversight of /AAs at the SEC, Report No. 460

This memorandum transmits the U.S. Securities and Exchange Commission,

OIG's final report detailing the results of our audit of the management and

oversight of interagency acquisition agreements. This audit was conducted in

accordance with our annual audit plan.

Based on the written comments received to the draft report and our assessment

ofthe comments, we revised the report accordingly. This report contains 15

recommendations to which the identified offices concurred with all but one

recommendation. OAS did not agree to recommendation 14. OFM and OHR did

not provide comments to the final draft report. OAS' comments to this report are

included in. the ·appendices..

Within the next 45 days, please provide OIG with a written corrective action plan

that is designed to address the recommendations. The corrective action plan

should include information such as the responsible official/point of contact, time

frames for completing the required actions, milestone dates identrtying how you

will address the recommendations cited in this report, etc.

G;J!M
Management and Oversight of lAAs at the SEC

Report No. 460

Page ii

March 26,2010

Should you have any questions regarding this report, please do not hesitate to

contact me. We appreciate the courtesy and cooperation that you and your staff

extended to our auditor.

Attachment

cc: Kayla J. Gillan, Deputy Chief of Staff, Office of the Chairman

Diego Ruiz, Executive Director, Office of the Executive Director

Wanda Armwood, Office of Administrative Services, Office of Acquisitions,

Assistant Director (Acting)
Management and Oversight of Interagency 

Acquisition Agreements at the SEC 

Executive Summary 

Background. Federal government agencies use interagency acquisition 

agreements (IAA) to obtain goods or services from or through other federal 

agencies. An interagency acquisition is a procedure by which a federal agency 

may obtain needed goods or services from, or through another federal agency, 

and appropriated funds are obligated. The IAA agreement refers to the legal 

instrument used for an interagency acquisition to exchange funds or property 

between two federal agencies. 

Goods and products that federal agencies obtain from other federal agencies 

through IAAs “include cars, equipment, manufactured goods, office space, 

supplies and other similar transactions where the providing agency 

manufactures, distributes or owns the assets which are sold or leased to the 

receiving agency.”1

 Services provided between agencies may “include 

administrative support, financial accounting and grants, disbursement of funds, 

consulting, telecommunication, childcare and other functions where the providing 

agency incurs costs to provide services and bills the receiving agency for the 

services.”2

 Agencies may place orders directly against another agency’s contract 

(direct acquisition), or have another agency award and administer the contract on 

its behalf (assisted acquisition). Interagency agreements for assisted 

acquisitions may involve a requesting agency, a servicing agency, and the 

contractor which provides the goods or services. 

The authority for federal agencies to obtain goods and services from each other 

is derived from various statutes. In the absence of specific statutory authority, 

the Economy Act (31 U.S.C. §§ 1535, 1536) provides general authority for 

interagency acquisitions. More specific authorities include: the Government 

Employees Training Act (5 U.S.C. Chapter 41), which allows agencies to obtain 

training and related assistance from other government agencies and the Office of 

Personnel Management; the Clinger-Cohen Act of 1996,3

 which authorizes 

information technology purchases, and 40 U.S.C. § 501, which relates to 

services for executive agencies granted to the Administrator of General Services. 

 

1

 Department of the Treasury, Financial Management Service, “Federal Intragovernmental Transactions 

Accounting Policies Guide,” Section No. 21.8 – Goods/Products, August 8, 2007 at p. 120. 2

 Id. at Section 21.7 – Services Provided, p. 117. 

3

 Also referred to as the “Information Technology Management Reform Act" (Pub. L. 104-106, Division E). 

Management and Oversight of IAAs at the SEC March 26, 2010 

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Management and Oversight of IAAs at the SEC March 26, 2010 

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The U.S. Securities and Exchange Commission’s (SEC or Commission) Office of 

Administrative Services, Office of Acquisitions (OA), oversees contracts and 

interagency acquisitions at the SEC. OA signs the funding documents to obligate 

funding on interagency acquisitions and resolves contractual issues regarding 

acquisitions. 

The SEC enters into many types of IAAs, including ones for administrative 

support services, employee payroll services, paralegal services, transit subsidies, 

and financial statement audit and human capital management assistance 

services. 

Objectives. The objectives of the audit were to: 

• Evaluate the SEC’s processes and procedures to approve, obtain, 

monitor, and close IAAs; 

• Assess compliance with governing federal and Commission regulations 

and polices by determining whether the interagency acquisition process is 

conducted in accordance with those regulations and policies, and whether 

the products and services meet quality, cost, and timeliness requirements; 

and 

• Determine whether opportunities exist for the SEC to save costs 

associated with IAAs. 

Prior OIG Audit Report. In a prior Office of Inspector General (OIG) audit on 

interagency agreements (Report No. 228, February 1, 1996), the OIG audited 11 

selected Commission interagency agreements and made 4 recommendations to 

the Office of Administrative and Personnel Management (OAPM, now the Office 

of Administrative Services) to improve controls. The recommendations were to: 

(a) Obtain proper documentation to support obligations of funds for the Health 

Unit and Employee Assistance Program; 

(b) Remind Contracting Officer Technical Representatives that they should 

notify the Procurement and the Contracts Branch upon satisfactory 

completion of small purchases; 

(c) Distribute guidance to ensure that purchases under the Economy Act were 

properly closed out; and 

(d) Use 18 U.S.C. § 4124, Purchase of prison-made products by federal 

departments, as authority for contracting with Federal Prison Industries. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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OAPM concurred with all four recommendations, issued additional guidance, and 

the recommendations were closed. However, we found that some of the areas 

previously identified in this audit still require improvement, particularly those 

relating to closeouts of Economy Act purchases. 

 

Results. Our audit found that OA can improve its processes and procedures 

regarding IAAs in a variety of ways. Initially, we found that OA is unable even to 

identify the universe of the SEC’s IAAs, and the incomplete list of IAAs that was 

provided to us contained numerous errors. We found that OA currently lacks a 

centralized method that accurately tracks all the SEC’s IAAs, although they are 

implementing an automated procurement tracking system. We also found that 

IAAs are not always clearly identified, thus hampering OA’s ability to track them 

appropriately. 

In addition, the audit found that OA lacks written internal policies and procedures 

for administering and overseeing IAAs. For example, OA has no SEC-specific 

written policies and procedures regarding: 

• Providing a specific, definite and clear description of products or services; 

• Ensuring that statements of work for assisted interagency acquisitions 

meet the applicable requirements; 

• Ensuring the reasonableness of interagency acquisition costs; 

• Including the appropriate information in interagency acquisition files; 

• Recording and maintaining complete information on interagency 

acquisitions; and 

• Closing expired interagency acquisitions. 

Further, OA has no written policies and procedures to implement the applicable 

provisions of the Federal Acquisition Regulation (FAR), the U.S. Department of 

Treasury Financial Manual (TFM) Bulletin No. 2007-03,4 or the Office of 

Management and Budget’s Office of Federal Procurement Policy (OFPP) 

guidance on interagency acquisitions. Also, OA’s IAAs do not undergo legal 

review and OA has not formulated policies regarding SEC oversight of IAAs. We 

also found that OA has not performed risk assessments of its interagency 

acquisition function. 

In scrutinizing the 133 SEC IAAs identified by OA, we found 23 IAAs, totaling 

approximately $6.9 million, for which the period of performance had expired, yet 

the IAAs were not closed out and the funds that remained on the IAAs were not 

deobligated. We found that $5.3 million of the $6.9 million in unobligated funds 

was attributed to a single IAA with General Services Administration (GSA) for 

which the period of performance ended on September 30, 2008. In this particular 

4 We note that the TFM Bulletin is not within the exclusive purview of OA but, after consulting with OA, it is 

our view that OA and OFM should work together to implement this Bulletin. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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instance, effective monitoring on the part of OA for this single IAA would have 

resulted in the $5.3 million being deobligated and returned to the Commission for 

use to support the SEC’s programs, operations and mission. 

We also found that OA lacked critical information to review IAA cost estimates. 

Specifically, we found in connection with an August 2008 IAA for administrative 

support services that the OA contracting officer was not able to explain why the 

SEC was paying a unit cost that was significantly higher than the estimated 

employee hourly rate and fringe rate. When we analyzed the costs associated 

with a judgmental sample of task orders, we found these costs contained a 

differential comprised of the vendor’s price to the government (including 

overhead, general and administrative expenses, and profit on direct labor 

cost/fringe benefits) of $281,000, representing 27 percent of the total cost of the 

corresponding task orders. We then compared this percentage to the fees 

associated with other SEC IAAs, and found it to be high. When we judgmentally 

selected 15 of 269 small business contractors listed on the GSA schedules that 

provided administrative support to agencies, we found that 9 of 15 contractors in 

our review listed lower rates than the entity the SEC chose in at least one labor 

category. We also found in connection with an IAA for payroll services that OA 

failed to provide necessary input to ensure that the proposed contract prices 

were fair and reasonable. 

Finally, we found that IAA documentation often lacked information required by 

the FAR, the TFM bulletin (Issued in 2007), and OFPP’s guidance (issued in 

2008), and the Office of Human Resources’ Statement of Work for a large IAA 

did not conform to the Office of Personnel Management’s guidance for the 

underlying program. 

Summary of Recommendations. This report consists of 15 recommendations 

that are intended to enhance OA’s controls regarding oversight of IAAs and 

improve its procedures, compliance with applicable requirements, and identifies 

cost saving opportunities. 

First, we recommend that OA identify its universe of open interagency 

acquisitions and the corresponding amounts obligated and expended on each 

interagency acquisition. Further, OA should maintain its interagency acquisition 

data in a centralized automated system to ensure appropriate access to and 

reliability of data, and to provide report generation capabilities. 

We also recommend that OA develop internal SEC-specific written policies and 

procedures to guide it in administering interagency acquisitions, and ensure that 

these policies and procedures include guidance on ensuring the adequacy of 

statements of work, ensuring the reasonableness of costs, maintaining adequate 

files and closing expired IAAs. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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Specifically, we recommend that OA take immediate action to close the IAAs we 

identified for which the performance period has expired and deobligate the 

corresponding $6.9 million in unused funds. 

We are also recommending that OA develop and implement procedures to 

review interagency acquisition cost estimates to ensure the estimates are 

reasonable, and assess an existing IAA for administrative support services to 

determine if the costs incurred are reasonable. 

Finally, we recommend that OA provide additional training to its contracting staff 

regarding interagency acquisitions. This training should include ensuring that 

statements of work meet the applicable guidance and requirements. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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TABLE OF CONTENTS 

Executive Summary............................................................................................. iii 

Table of Contents...............................................................................................

Background and Objectives

Background ....................................................................................................

Objectives ......................................................................................................

Findings and Recommendations

Finding 1: OA Is Unable to Identify the Universe of the SEC’s Interagency 

Agreements....................................................................................................

Recommendation 1.....................................................................................

Recommendation 2.....................................................................................

Recommendation 3.....................................................................................

Finding 2: OA Lacks Written Internal Policies and Procedures for Interagen

Acquisitions ....................................................................................................

Recommendation 4.....................................................................................

Recommendation 5.....................................................................................

Recommendation 6.....................................................................................

Finding 3: OA Maintained Funds on IAAs for Which the Period of Performa

Ended.............................................................................................................

Recommendation 7.....................................................................................

Recommendation 8.....................................................................................

Recommendation 9.....................................................................................

Finding 4: IAA Documentation Lacked Information Required by the FAR an

Treasury Guidance.........................................................................................

Recommendation 10...................................................................................

Finding 5: OA Lacked Adequate Information to Review IAA Cost Estimates

Recommendation 11...................................................................................

Recommendation 12...................................................................................

Recommendation 13...................................................................................

Finding 6: OHR’s Statement of Work for its Human Resources Manageme

Assistance IAA Did Not Conform to OPM’s TMA Program Guidance ............

Recommendation 14...................................................................................

Recommendation 15...................................................................................

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Management and Oversight of IAAs at the SEC March 26, 2010 

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Appendices 

 Appendix I: Acronyms.................................................................................33 

 Appendix II: Scope and Methodology ........................................................

 Appendix III: Criteria ...................................................................................

 Appendix IV: List of Recommendations ......................................................

 Appendix V: Management Comments .......................................................

 Appendix VI: OIG Response to Management’s Comments ........................

Appendix VII: Table 3: Universe of IAAs Provided by OAS........................

Appendix VIII: Table 4: Duplicates, Amendments & Errors........................

Appendix IX: Table 5: Expired IAAs w/Outstanding Funding .....................

Appendix X: Table 6. Schedule of Cost Savings .......................................

Tables 

 Table 1: Intragovernmental Business Rules Procurement Requirements

Table 2: OPM/TMA Program Interagency Agreement Guidance Steps....

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Background and Objectives

Background 

Purpose of Interagency Acquisitions. Over the years, the use of interagency 

acquisitions by federal agencies has grown considerably. This growth has 

occurred as agencies have taken advantage of contracts and acquisition services 

offered by other federal agencies. The use of interagency acquisitions 

agreements (IAA) allows an agency to obtain goods or services by using another 

agency’s contract, and/or by having another agency provide acquisition 

assistance.5 Federal agencies use interagency agreements to save time and 

the administrative effort that can be associated with soliciting and awarding a 

new contract for needed goods or services. 

 

An IAA typically is a written agreement between federal agencies for goods or 

services, on a reimbursable basis. IAAs are developed when an agency 

(requesting agency) uses the contracts and/or services of another agency 

(servicing agency) to obtain good or services. The requesting agency places the 

order for goods and services. The servicing agency provides acquisition support, 

administers the contract for the requesting agency’s direct use, or does a 

combination of these things. Both the requesting and servicing agencies can 

benefit from IAAs. A requesting agency can benefit from the servicing agency’s 

expertise and capabilities and the efficiencies and economies from leveraging 

resources and requirements.6 A servicing agency can benefit from improved 

pricing and terms and conditions that come from negotiating other agencies’ 

needs consolidated with their own needs.7 A requesting agency should choose a 

servicing agency that provides the necessary assistance by giving consideration 

to the servicing agency’s authority, experience, and expertise; ability to comply 

with the requesting agency’s laws and policies; customer satisfaction with the 

servicing agency’s past performance; and reasonableness of the servicing 

agency’s fees.8

 With regard to assisted acquisitions (see below), requesting and 

servicing agencies should develop clear and complete agreements that establish 

the general terms and conditions to govern the relationship and provide 

information required to demonstrate a bona fide need to authorize the transfer 

and obligation of funds.9

5

 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy, “Interagency Acquisitions,” June 2008 at p.2. 6

 Id. 

7

 Id. 

8

 Id. at pgs. 6-7. 

9

 Id. at p.6. 

Management and Oversight of IAAs at the SEC March 26, 2010 

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Management and Oversight of IAAs at the SEC March 26, 2010 

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Agencies generally use one of two types of IAAs: (1) Direct acquisitions or 

(2) Assisted acquisitions. In direct acquisitions, the requesting agency places an 

order against the servicing agency’s existing contract. In an assisted acquisition, 

the servicing agency and the requesting agency enter into an IAA, whereby the 

servicing agency performs acquisition activities, such as awarding a contract.10 

Authority and Processes for Interagency 

Acquisitions 

Economy Act vs. Non-Economy Act Agreements. IAAs are issued either 

under the general authority of the Economy Act, 31 U.S.C. §§1535, 1536, or in 

accordance with statutory authority other than the Economy Act. A major 

difference between Economy Act and non-Economy Act IAAs pertains to the 

deobligation of funds. The Economy Act allows “[t]he head of an agency or a 

major organizational unit within an agency to place an order with a major 

organizational unit within the same agency or another agency for goods or 

services -- 

(1) Amounts are available; 

(2) The head of the ordering agency or unit decides the order is in the best 

interest of the United States Government; 

(3) The agency or unit to fill the order is able to provide or get by contract the 

ordered goods and services; and 

(4) The head of the agency decides ordered goods or services ordered 

cannot be provided by contract as conveniently or cheaply by a commercial 

enterprise.”11 

An Economy Act transaction should be evidenced by a written agreement, which 

is important to “establish the scope of the undertaking and the rights and 

obligations of the parties.”12 The Government Accountability Office (GAO) 

recommends that the written agreement specify at least the following items: 

• Legal authority for the agreement; 

• Terms and conditions of performance; 

• The cost or performance, including appropriate ceilings when cost is 

based on estimates; 

• Mode of payment (advance or reimbursement); 

10 Id. at p. 2. 11 31 U.S.C. § 1535(a). 12 U.S. Government Accountability Office, Principles of Federal Appropriations Law, Third Edition, Volume 

III, GAO-08-978SP, September 2008 at pgs. 12-30. The recording statute, 31 U.S.C. § 1501 requires 

documentary evidence for government obligations. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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n 

 

• Any applicable special requirements or procedures for assuring 

compliance; and 

• Approvals by authorized officials.13

IAAs based on statutory authority other than the Economy Act are still subject to 

the recording of the obligation requirement of 31 U.S.C. § 1501(a) (1).14

A major difference between Economy Act and non-Economy Act IAAs pertains to 

the deobligation of funds. For Economy Act acquisitions, the amount of funds 

obligated “is deobligated to the extent that the agency or unit filling the order has 

not incurred obligations, before the end of the period of availability of the 

appropriation in -- (1) providing goods or services; or (2) making an authorized 

contract with another person to provide the requested goods or services.”15 The 

deobligation requirement of 31 U.S.C. § 1535(d), however, “does not apply to 

obligations against no-year appropriations.”16 The deobligation requirement of 

31 U.S.C. § 1535(d) also does not apply to interagency agreements based o

statutory authority other than the Economy Act.17

Office of Acquisitions. The U.S. Securities and Exchange Commission’s (SEC 

or Commission) Office of Administrative Services (OAS), Office of Acquisitions 

(OA) oversees the Commission’s contracts and interagency acquisitions. OA 

includes four branches, consisting of a newly-established Policy, Oversight and 

Acquisitions Program branch and three Operations Contract branches. One 

operations contract branch oversees acquisitions for the Office of Information 

Technology. The second branch has oversight for acquisitions by OAS, the 

Office of Human Resources (OHR), and the regional offices. The third branch 

oversees acquisitions for the Division of Enforcement, Office of the Secretary, 

and other headquarters offices and divisions, and regional office’s enforcement 

actions. The responsibilities of staff in OA’s Operations Contract branches 

includes signing IAA funding documents to obligate funding, resolving issues 

regarding acquisitions, and ensuring agreements are properly closed out after 

the period of performance expires. 

IAA Process for SEC Offices and Divisions. SEC’s offices and divisions 

initiate an IAA by contacting another government agency directly to discuss 

needed requirements, terms and conditions, or by submitting a requirement to 

OA. If an SEC office or division contacts another government agency directly, 

13 Id. at pgs. 12-31. 14 U.S. Government Accountability Office, Principles of Federal Appropriations Law, Third Edition, Volume II, 

GAO-06-382SP, February 2006 at pgs. 7-30. 

15 31 U.S.C. § 1535(d). 16 U.S. Government Accountability Office, Principles of Federal Appropriations Law, Third Edition, Volume II, 

GAO-06-382SP, February 2006 at pgs. 7-30. 

17 Id. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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the SEC office or division must provide OA with the purchase requisition for 

funding, the unsigned IAA agreement form, the statement of work (SOW), and 

the terms and conditions of the agreement. If OA initiates the IAA, the office or 

division must send the SOW to OA, and OA contacts the other government 

agency to establish the terms and conditions of the IAA. If OA and the servicing 

agency approve the agreement, representatives of both agencies sign the IAA 

form. The servicing agency then establishes payments for the IAA through the 

Interagency Payment and Collection (IPAC) system. OA uses the signed IAA 

agreement order to obligate funding for the goods or services by inputting 

required information into Momentum, the Commission’s financial system. 

Intra-Governmental Payments and Collection System. The Commission uses 

the IPAC system to pay its IAA invoices. The IPAC system uses financial 

information provided by the SEC to set up automatic billing and charges on a 

periodic basis, as agreed to in the terms and conditions of the IAA. The servicing 

agency draws down on the SEC’s funds and then sends a notice to the Office of 

Financial Management (OFM). OFM coordinates with the servicing agency, as 

well as with the SEC program office or division that receives the goods and 

services to verify the amount collected through IPAC. If the invoiced amount 

does not represent what was actually received, OFM processes an adjustment in 

IPAC to “charge back” the erroneous amount to the Commission’s account. This 

ensures the SEC only pays for the goods and services that are received. 

 

Objectives 

This audit was conducted as part of our annual audit plan. The objectives were 

to: 

• Evaluate the Commission’s processes and procedures to approve, obtain, 

monitor, and close IAAs; 

• Assess compliance with governing federal and Commission regulations 

and polices by determining whether the process is conducted in 

accordance with those regulations and policies, and whether the products 

and services meet quality, cost, and timeliness requirements; and 

• Determine whether opportunities exist for the SEC to save costs 

associated with IAAs. 
Findings and Recommendations 

Finding 1: OA Is Unable to Identify the Universe 

of the SEC’s Interagency Agreements 

OA cannot accurately identify the Commission’s 

universe of interagency acquisitions and the list of 

IAAs that was provided was incomplete and had 

numerous errors. 

Review of OA’s Interagency Acquisition List. As part of this audit, we 

requested OA provide us with the universe of IAAs that were open, initiated or for 

which the period of performance ended during fiscal years (FY) 2007 - 2009. We 

learned that OA does not have a centralized system to track or identify the 

universe of its IAAs. Although OA provided us with a list of 133 IAAs,18 totaling 

approximately $234 million in estimated costs, the complete universe of IAAs 

could not be confirmed, and we found that the list provided to us was incomplete 

and contained erroneous information. Thus, OA officials could not identify the 

total number or dollar amount of the Commission’s IAAs with certainty. 

In our review of the 133 IAAs OA identified on its list (See Table 3, in Appendix 

VII for the complete list), we found the following information missing from the list: 

• Period of performance was missing for 63 IAAs; 

• Obligated amounts was missing for 50 IAAs; 

• IAA status was missing for 49 IAAs; 

• Statutory authority was missing for 48 IAAs. 

Furthermore, we found 4 IAAs were inaccurately identified on OA’s list of IAAs as 

“expired” when, in fact, according to the IAAs themselves, the period of 

performance had not ended. Due to the number of errors found on OA’s list of 

IAAs, we determined that the IAA list was unreliable. We therefore concluded 

that the list does not provide OA with reliable information that can be used to 

make decisions on IAAs. 

OA’s Interagency Acquisition Tracking Method. We also found that OA lacks 

a centralized method that accurately tracks and identifies all of the SEC’s IAAs. 

 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 5 

18 The list provided by OA actually contained 176 items. However, after adjusting for duplicates, 

amendments and items that were not IAAs, the list yielded a total of 133 IAAs. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 6 

This deficiency could negatively impact both the agency’s ability to report 

financial information accurately and its ability to oversee and manage 

interagency acquisitions. OA branch chief’s/contracting officers primarily track 

the IAAs under their purview differently, on separate spreadsheets. In addition, 

OA does not have SEC-specific written policies or procedures to identify the 

information that the branch chief’s/contracting officers should track or what data 

should be included in the spreadsheets. 

OA informed the OIG that once PRISM, its new automated procurement system, 

is fully functional, OA will devise a method to better track IAA data in PRISM. 

PRISM’s implementation consists of three phases and OA is currently in phase 

two of the implementation. At the time fieldwork for this audit was completed, all 

IAAs were not loaded into PRISM. 

The absence of written, standardized processes and procedures to track IAAs 

makes it difficult for OA to monitor, revise, and update IAA data on a 

Commission-wide basis, or to ensure that the SEC is complying with all 

applicable federal requirements, such as the Federal Acquisition Regulation 

(FAR). 

IAA Number String and Budget Object Class. We also found that IAAs are 

not always clearly identified by the IAA number string. Many IAA numbers 

include the letter “H,” such as SECHQ1-09-H-XXXX as an indication that an IAA 

is involved, rather than a contract. However, we identified 12 IAAs on the list 

provided by OA that had an “F” in the IAA number string, rather than an “H.” The 

letter “F” is generally utilized to refer to a delivery order, not an IAA. We also 

identified additional IAAs that did not have either the letter “H” or the letter “F” in 

the number string. 

Having an identifiable letter in the IAA number enables OA staff, contracting 

officers, contract specialists, Contracting Officer's Technical Representatives 

(COTR), program officers and others, to track the Commission’s IAAs. OA 

indicated that it will standardize the naming conventions for IAAs in PRISM and 

will include an “H” in all future IAA numbers, so they can be more readily tracked 

and managed. 

Prior Audit Work Conducted. Regis & Associates, PC (Regis), under contract 

with the OIG, performed an audit of OA’s procurement and contract management 

processes and functions and issued the report Audit of the Office of Acquisitions’ 

Procurement and Contract Management Functions, Report No. 471, September 

2009. The scope of Regis’ review covered FYs 2006 to 2008. Regis also found 

that OA could not identify the universe of its contracts and the corresponding 

contract values. The report consisted of 10 recommendations, including requiring 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 7 

OA to identify the universe of open contracts and the corresponding value of the 

contracts. 

Recommendation 1:

The Office of Acquisitions (OA), in coordination with the Office of Financial 

Management (OFM), should identify its universe of open interagency 

acquisitions and the corresponding amounts obligated and expended on 

each interagency acquisition. Once this is accomplished, OA should 

reconcile its universe of active and open interagency acquisitions with the 

financial information maintained by OFM regarding active and open 

interagency acquisitions and the corresponding amounts obligated and 

expended. 

Management Comments. OA and OFM: Concur. OFM did not provide 

written or verbal comments to the formal draft report. See Appendix VI for 

OA’s full comments to the report. 

OIG Analysis. We are pleased that OA and OFM have concurred with 

this recommendation. 

Recommendation 2:

The Office of Acquisitions should maintain its interagency acquisition data 

in the appropriate centralized automated system to ensure appropriate 

access to and accuracy of data and to provide for report generation 

capabilities. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Recommendation 3:

The Office of Acquisitions should establish appropriate internal controls to 

provide reasonable assurance that, in the future, interagency acquisition 

agreement data is accurate, timely, complete and reliable. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 8 

 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Finding 2: OA Lacks Written Internal Policies 

and Procedures for Interagency Acquisitions 

 OA does not have written internal policies and 

procedures for handling interagency acquisitions at 

the SEC. The lack of written internal policies and 

procedures is an internal control weakness that limits 

the ability of OA staff to ensure the proper use of 

IAAs. 

Lack of SEC-Specific Written Internal Policies and Procedures for IAAs. 

Our audit found that OA had not developed sufficient internal SEC-specific 

written policies and procedures to guide its administration of IAAs. For example, 

OA has no SEC-specific policies and procedures regarding: (a) providing a 

specific, definite and clear description of products or services; (b) ensuring that 

statements of work for assisted interagency acquisitions meet the applicable 

requirements; (c) ensuring the reasonableness of interagency acquisition costs; 

(d) including the appropriate information in interagency acquisition files; 

(e) recording and maintaining complete information on interagency acquisitions; 

and (f) closing expired interagency acquisitions. Further, OA has no written 

policies and procedures to implement applicable provisions of the FAR, Treasury 

Financial Manual (TFM) Bulletin No. 2007-03, or the Office of Management and 

Budget’s Office of Federal Procurement Policy (OFPP) guidance regarding 

interagency acquisitions. Also, we found that OA’s IAAs do not undergo any 

legal review,19 and OA has not formulated policies regarding SEC oversight of 

IAAs, pursuant to OA’s Memorandum of Understanding with the Office of 

General Counsel.

The acquisition-related policies and procedures issued by OA do not relate to 

IAAs per se, and include the following: 

• SECR 10-2, SEC Contracting Authorities and Appointments, 

September 23, 2009 - Establishes the uniform policies and 

procedures for acquisition of products and services for the SEC. 

19 Pursuant to the Memorandum of Understanding, dated September 13, 2005, between the Office of the 

General Counsel and the Office of Administrative Services, “Statement of Policy on Legal Review of 

Procurement Actions,” OGC review and involvement will normally not be required in routine situations 

involving interagency agreements, regardless of contract value. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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• SECR 10-14, Contract Administration, April 28, 2005 - Establishes 

the Commission’s contract closeout program and explains how it 

functions, and implements 48 C.F.R. § 4.8, Government Contract 

Files, 48 C.F.R. § 17.5, Interagency Acquisitions under the 

Economy Act, and 48 C.F.R. § 42.708, Quick-closeout Procedure. 

The regulation applies to contracting officers, contract specialists, 

COTRs and program managers/officials who are involved in the 

acquisition of supplies and services. The regulation states that the 

closeout procedures are applicable to all contracts, and Economy 

Act acquisitions. However, OA officials have informed the OIG that 

they do not follow these procedures for IAAs because in OA’s view, 

these procedures do not apply to IAAs. 

Written policies and procedures represent an organization’s documented internal 

control activities. According to GAO’s “Standards for Internal Control in the 

Federal Government,” in implementing the standards for internal control, 

“management is responsible for developing the detailed policies, procedures, and 

practices to fit their agency’s operations and to ensure that they are built into and 

an integral part of operations . . . .”20 

Lack of SEC Policies Implementing the Office of Management and Budget’s 

Office of Federal Procurement Policy 2008 Guidance. The Office of 

Management and Budget’s (OMB) OFPP Guidance on “Interagency 

Acquisitions,” issued on June 6, 2008, became effective in part on October 1, 

2008, and in part on or after November 3, 2008.21 The guidance identifies the 

responsibilities for both the requesting agency and servicing agency, and 

provides generalized descriptions of their roles. For example, the OFPP 

determined that “[t]o ensure sound management and use of interagency 

acquisitions and maximize their impact on agency effectiveness, requesting and 

servicing agencies must establish clear lines of responsibility for each step in the 

acquisition lifecycle, from planning to contract closeout . . . .“22 The OFPP 

guidance also requires requesting agencies to “[p]rovide documentation to the 

Servicing Agency, which may be in the form of a SOW, statement of objectives 

(SOO), or performance work statement, that includes a specific, definite, and 

clear description of a bona fide need . . . .”23 Servicing agencies are required to 

“[e]nsure requirements are clearly defined and suitable performance standards 

20 U.S. Government Accountability Office, “Standards for Internal Control in the Federal Government,” 

GAO/AIMD-00-21.3.1, November 1999, p.7. 21 See Memorandum for Chief Acquisition Officers, Senior Procurement Executives, from Paul A. Denett, 

Administrator, Office of Federal Procurement Policy, and Subject: Improving the Management and Use of 

Interagency Acquisitions, June 6, 2008. 

22 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy, “Interagency Acquisitions,” Appendix 1, Checklist of Roles and Responsibilities in Assisted 

Acquisitions at p. 14. 

23 Id. at p. 17 (emphasis in original). 
Management and Oversight of IAAs at the SEC March 26, 2010 

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are established against which results may be effectively measured.”24 

Additionally, the OFPP guidance provides requirements for developing 

interagency acquisition documents. We were informed during the course of the 

audit that copies of the OFPP guidance were distributed to OA staff. However, 

we were not provided with any written documentation concerning how OA 

intended to implement the OPFF guidance. We determined that OA should tailor 

the generalized descriptions identified in this guidance to fit its specific 

circumstances. 

Failure to Incorporate Treasury Financial Manual Bulletin. The U.S. 

Department TFM Bulletin No. 2007-03, “Intragovernmental Business Rules,” 

became effective on October 1, 2006. The TFM bulletin provides guidance for 

recording and reconciling intragovernmental transactions, including interagency 

acquisitions whereby agencies obtain goods and services from each other by 

means of an intragovernmental agreement or order. The TFM bulletin includes 

requirements for the documentation of intragovernmental agreements or orders. 

Specifically, in Section VI, “Procurement Requirements,” of the TFM bulletin 

identifies specific information to be included in intragovernmental acquisition 

order documents, such as, the agreement number, the effective date and 

duration of the agreement, the amount and method of payment, etc. 25

 

The TFM bulletin’s policies and procedures represent the internal controls that 

OA and OFM should use to ensure that interagency acquisitions are 

appropriately accounted for and recorded. These government-wide requirements 

should all be incorporated into OA’s written polices and procedures for 

interagency acquisitions. 

Improper Reliance Upon FAR Subpart 17.5 Guidance for Interagency 

Acquisitions. OA relied on FAR Subpart 17.5, “Interagency Acquisitions Under 

the Economy Act,” (FAR 17.5) as its guidance for interagency acquisitions. FAR 

17.5 implements the Economy Act and “. . . . prescribes policies and procedures 

applicable to interagency acquisitions under the Economy Act . . . .”26 According 

to FAR 17.5, agencies must provide documentation that the interagency 

acquisition is in the best interest of the government and that the goods or 

services could not be obtained as cheaply or conveniently from a private 

source.27 FAR 17.5 also provides for ordering and payment procedures related 

to interagency acquisitions.28 

24 Id. at p. 20. 25 Department of the Treasury, Treasury Financial Manual Bulletin No. 2007-03, effective October 1, 2006, 

Attachment 1, “Intragovernmental Business Rules” at pgs. 6-7. 26 48 C.F.R. § 17.500(a). 27 48 C.F.R. § 17.503(a). 28 48 C.F.R. §§ 17.504, 17.505. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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FAR Subpart 17.5 does not, however, apply to non-Economy Act acquisitions, or 

provide guidance for agency-specific situations. For example, FAR 17.5 would 

not apply to interagency acquisitions using Government-Wide Acquisition 

Contracts or Federal Supply Schedule contracts. Acquisition of training services 

from the Office of Personnel Management under the Government Employees 

Training Act also would not be covered by FAR 17.5. 

The distinction between Economy Act and non-Economy Act authority can be 

important because for Economy Act acquisitions, the IAA funds must be 

deobligated after the period of fund availability expires if the servicing agency has 

not supplied the requested goods or services or entered into a valid contract to 

do so. This requirement applies to Economy Act IAAs with funding that has 

specific periods of availability (annual or multi-year appropriations). This 

requirement does not apply to non-Economy Act IAAs. Also, FAR 17.5, which 

applies to Economy Act acquisitions, prohibits servicing agencies from collecting 

fees or charges in excess of actual or estimated costs.29 This FAR requirement 

does not apply to non-Economy Act IAAs. 

Our audit found that the Economy Act was cited as the only authority for the 

agreements in all instances for which an authority was cited. Though an 

authority was cited in 85 of 133 instances, not all of these acquisitions were 

authorized under the Economy Act because some acquisitions, e.g., GSA 

acquisitions, were authorized by specific statutes other than the Economy Act.30 

Failure to Perform Risk Assessments. OA also has not performed risk 

assessments of its interagency acquisition function. Risk assessments would 

help OA to manage its IAAs better by identifying actual and potential 

opportunities and challenges related to the IAAs. OA could then develop policies 

and procedures to take advantage of the opportunities identified through the risk 

assessments and to address its challenges in managing IAAs. 

Without written procedures for interagency acquisitions, OA lacks adequate 

guidance needed for administering IAAs. The audit report further identified a 

number of instances where such guidance would have been useful. For 

example, OA did not have written guidance for: 

 

• Ensuring that SOWs for assisted IAAs meet the applicable 

requirements (See Finding 6); 

29 48 C.F.R. § 17.505(d). 30 According to FAR Subpart 17.500(b), “[t]he Economy Act applies when more specific statutory authority 

does not exist. Examples of interagency acquisitions to which the Economy Act does not apply include— 

(1) Acquisitions from required or optional sources of supplies prescribed in [FAR] Part 8, which have 

separate statutory authority (e.g., Federal Supply Schedule contracts); and (2) Acquisitions using 

Governmentwide acquisition contracts.” 48 C.F.R. § 17.500(b). 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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• Ensuring the reasonableness of IAA costs (See Finding 5); 

• Including the appropriate information in IAA documents (See Finding 

4); 

• Recording and maintaining complete and accurate information on IAAs 

(See Finding 1); and 

• Closing out expired IAAs (See Finding 3). 

Other Government Agencies’ Written Policies and Procedures for IAAs. We 

identified several government agencies that have written policies and procedures 

regarding the oversight of both Economy Act and non-Economy Act IAAs. We 

also found that OMB’s OFPP IAA guidance requires that requesting agencies 

obtain legal review, as needed.31 Specifically, the Department of the Interior 

(DOI) has an internal IAA handbook that identifies the general policies and 

procedures for preparing, reviewing, approving, monitoring, and closing IAAs.32 

The Department of Homeland Security has written policies and procedures for 

IAAs under the Economy Act.33 The Department of Energy developed written 

policies and procedures covering interagency acquisitions pursuant to the 

Economy Act, Government-Wide Acquisition Contracts, the General Services 

Administration Federal Supply Schedule, and Franchise Fund organizations.34 

OA should explore reviewing the existing guidance that other agencies have 

developed for managing the oversight of IAAs, and benchmark best practices 

when developing its own written policies and procedures. 

Recommendation 4: 

The Office of Acquisitions should develop internal written policies and 

procedures to guide it in administering interagency acquisitions. These 

policies and procedures should be based on appropriate risk 

assessments, address both Economy Act and Non-Economy Act 

acquisitions, and incorporate Federal Acquisition Regulation Subpart 17.5, 

the Office of Federal Procurement Policy’s guidance on interagency 

acquisitions, and other requirements regarding interagency acquisitions as 

appropriate. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

31 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy, “Interagency Acquisitions” at p. 16. 32 Department of the Interior Inter/Intra-Agency Acquisition Handbook, 4/3/2008 version, 

www.doi.gov/pfm/handbooks/iaa.pdf. 

33 Department of Homeland Security, Directive No. 125-02, “Interagency Agreements,” August 15, 2008 34 Department of Energy Acquisition Letter, No. 2005-05 Rev, “Interagency Contracting,” April 26, 2005. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Recommendation 5: 

In developing written policies and procedures for assisted interagency 

acquisitions the Office of Acquisitions should incorporate the requirements 

of the Economy Act, the Office of Federal Procurement Policy guidance on 

interagency acquisitions, and other controlling authorities, and coordinate 

with the Office of Financial Management to assure its minimum 

requirements are also included. The Office of Acquisitions should ensure 

that its written policies and procedures for interagency acquisitions include 

guidance on: 

• Ensuring that statements of work for interagency acquisitions 

related to assisted services meet the applicable requirements; 

• Ensuring the reasonableness of interagency acquisition costs; 

• Including the appropriate documents in interagency acquisition 

files; 

• Recording and maintaining complete information on interagency 

acquisitions; and 

• Closing expired interagency acquisitions. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Recommendation 6:

The Office of Acquisitions should benchmark other federal agencies’ 

written policies and procedures for interagency acquisitions when 

developing its interagency acquisition agreement written policies and 

procedures. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Finding 3: OA Maintained Funds on IAAs for 

Which the Period of Performance Ended 

We found 23 of 133 IAAs, totaling approximately $6.9 

million, for which the period of performance had 

ended, yet the IAAs were not closed out and the 

funds that remained on the IAA were not deobligated. 

Expired IAAs Funds Were Not Deobligated. The SEC uses no-year money to 

fund its IAAs. No-year funding can be carried into future fiscal years, and the 

funds can be made available for the agency’s use. Thus, no-year money is 

available for use until it is spent. 

Our audit initially found 30 of 133 IAAs identified on the list OA provided to the 

OIG had expired and the period of performance had ended. We searched the 

Commission's financial accounting system, Momentum,35 to confirm whether 

funding remained on the IAAs. We then provided a copy of our list of expired 

IAAs to OA, who researched and revised our list. OA identified a duplicate IAA 

on our list and 6 IAAs that were still active. After OA’s review and concurrence, 

we determined that there were 23 of 133 expired IAAs having approximately $6.9 

million in funds that had not been deobligated. Although the IAAs’ period of 

performance had expired, the IAAs were not closed out and the funds were not 

deobligated. We found that approximately $5.3 million of the $6.9 million in 

obligated funds was attributed to a single IAA with GSA, for which the period of 

performance ended on September 30, 2008. To date, this IAA has not been 

closed. This $6.9 million represents funds identified by the OIG that are 

considered cost savings and/or funds put to better use.36 A detailed list of the 

expired IAAs with outstanding funding and the obligated amounts can be found in 

Table 5, located in Appendix IX. 

OA officials acknowledged that the 23 IAAs had expired, had not been closed 

out, and the funding was not deobligated. They stated that this occurred 

because of OA’s heavy workload, resource limitations, and the low priority placed 

on conducting closeouts. As a result, $6.9 million in unused funds has remained 

on the expired IAAs that have not been deobligated. Since the obligated 

amounts came from no-year money, these funds could be used to support the 

SEC’s current programs, operations and mission. (See Appendix IX and 

Appendix X) OA officials informed the OIG that it intends to closeout these IAAs 

and deobligate any remaining funds, beginning in the first quarter of FY 2010.

35 The Momentum system tracks the agency's budget, obligations, expenditures and balances. 36 See Table 6 at Appendix X. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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SECR Closeout Requirements. SECR 10-14, Contract Administration, provides 

guidance on contract closeouts and dictates closure dates for specific contract 

types, such as simplified acquisitions and firm-fixed price contracts, other than 

simplified acquisitions. The regulation provides that “[f]iles for all other contracts 

should be closed within 20 months of the month in which the contracting 

officer/specialist receives evidence of physical completion.”37 The regulation also 

states that it implements FAR 17.5 for interagency acquisitions that are subject to 

the Economy Act. However, we found that OA does not have any written 

guidance that specifically addresses IAA closeout procedures.38 

Moreover, OA officials informed the OIG that it does not follow the SECR 10-14 

closeout procedures for IAAs because OA determined the guidance does not 

apply to IAAs. Instead, OA officials indicated they rely on FAR 17.5 for all IAA 

guidance. However, FAR 17.5 provides no guidance for IAA closeout 

timeframes, processes, or procedures, and it does not address non-Economy Act 

acquisitions. We determined that in the absence of specific closeout procedures 

for IAAs, OA should have ensured that IAAs were properly closed, particularly in 

light of SECR 10-14’s representation that it applies to all Economy Act 

acquisitions. 

According to OA, the contracting officer is responsible for deobligating funds that 

remain on IAAs, as well as for adding funds that may be needed. With assisted 

acquisitions, the contracting officer is located at the servicing agency, not at the 

SEC. Therefore, the servicing agency is responsible for closing the IAA with the 

vendor. In fact, based on the terms of the expired IAA with GSA, we found that 

GSA should have closed the IAA but failed to do so. Our audit also found that 

OA contracting officers, contract specialists, and COTRs did not effectively 

monitor IAAs to ensure they were closed in a timely manner and unused funds 

were properly deobligated. Upon GSA’s completion of closing out the IAA, any 

funds left over should have been returned to the SEC. Effective monitoring on 

the part of the SEC would have resulted in $5.3 million being deobligated and 

returned to the Commission in a timely manner. 

We further found that OA staff had contact with the servicing agencies during the 

IAAs, but OA does not have or follow standard written procedures for 

coordinating closeouts with the servicing agencies. OA should develop and 

follow written procedures for COTR oversight of payments and funding and 

coordinating IAA closeouts with servicing agencies. This will ensure that the 

SEC’s unused funds are properly returned and that the funds are put to better 

use by the Commission.

37 SECR 10-14, “Contract Administration,” April 28, 2005, Section 2a. 38 While the Office of Acquisitions indicated that there are FAR provisions for close-out of contract files, 

SEC-specific written guidance for close-out of IAAs is recommended. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Recommendation 7:

The Office of Acquisitions should develop written policies and procedures 

regarding interagency acquisitions that include timeframes and 

procedures for closing out Economy Act and non-Economy Act 

interagency acquisitions and deobligating funds for both assisted and 

direct acquisitions. The closeout procedures should also identify the 

Commission’s process for coordinating with servicing agencies. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Recommendation 8:

The Office of Acquisitions should promptly identify fully all interagency 

acquisition agreements that have expired and have not been closed. The 

Office of Acquisitions should further deobligate any funds that remain on 

the expired agreements. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 

Recommendation 9: 

The Office of Acquisitions should take action to close the interagency 

acquisitions we identified for which the performance expired and 

deobligate the $6.9 million in unused funds that remain on the interagency 

acquisitions, in accordance with the appropriate close-out procedures. 

Management Comments. Concur. See Appendix VI for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurred with this 

recommendation. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Finding 4: IAA Documentation Lacked 

Information Required by the FAR and 

Treasury Guidance 

The SEC’s IAA forms and the determinations and findings 

(D&F) lacked information required by the FAR. We further 

found that the “Securities and Exchange Commission (SEC) 

Interagency Agreement/Amendment” form is outdated, and 

that the SEC’s IAA award documents and forms did not 

include all of the information necessary to document the 

basis for the interagency acquisition and the obligation of 

funds. 

FAR Compliance: Economy Act Determinations and 

Findings Documents 

FAR 17.503. According to FAR section 17.503(a), “[e]ach Economy Act order 

shall be supported by a D&F. The D&F shall state that— 

(1) Use of an interagency acquisition is in the best interest of the 

Government; and 

(2) The supplies or services cannot be obtained as conveniently 

or economically by contracting directly with a private source.”39 

FAR 17.503(b) provides that “[i]f the Economy Act order requires contract action 

by the servicing agency, the D&F must also include a statement that at least one 

of the following circumstances applies: 

(1) The acquisition will appropriately be made under an existing 

contract of the servicing agency, entered into before placement 

of the order, to meet the requirements of the servicing agency 

for the same or similar supplies or services; 

(2) The servicing agency has capabilities or expertise to enter 

into a contract for such supplies or services which is not 

available within the requesting agency; or 

39 48 C.F.R. § 17.503(a). 
Management and Oversight of IAAs at the SEC March 26, 2010 

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(3) The servicing agency is specifically authorized by law or 

regulation to purchase such supplies or services on behalf of 

other agencies.”40

Review of Determinations and Findings. We reviewed D&Fs from a 

judgmental sample of 13 of 133 IAAs to evaluate compliance with the FAR. Of 

the 13 IAAs that were selected for review, 4 were covered by the Economy Act, 

and 9 were non-Economy Act acquisitions. Also, 5 of 13 IAAs were assisted 

acquisitions, while 8 were direct acquisitions. Our review found that 3 of the 13 

D&F documents, 2 which were for Economy Act IAAs, lacked the required 

statement that “[t]he supplies or services cannot be obtained as conveniently or 

economically by contracting directly with a private source.” We also found that 

1of 13 D&F documents was not signed by a contracting officer, as is required by 

FAR 17.503(c). 

The D&F requirements provide documented justification for entering into 

interagency acquisitions. The D&F documents that were incorrectly completed, 

therefore, did not provide adequate justification for the related interagency 

acquisitions.41

The SEC’s Interagency Agreement/Amendment Form. The Securities and 

Exchange Commission (SEC) Interagency Agreement/Amendment, (SECIAA/A) 

form was last revised in 1999. We judgmentally selected 21 IAAs from our 

population of 133 IAAs. We found that 10 of the 21 selected IAAs were prepared 

on the SEC’s award forms, while the remaining 11 IAAs were prepared on the 

other agencies’ forms. 

In reviewing our sample, we found that while the SECIAA/A forms include 

information required by FAR 17.503, the forms lack specific fields needed to 

identify delivery requirements, acquisition authority, and the resolution of 

disagreements, as required by TFM Bulletin No. 2007-03. The IAA award forms 

simply have a catchall field “Additional instructions/Information” that may or may 

not contain this information. While information such as delivery requirements 

was contained in this field on several of the forms, we found five SECIAA/A forms 

that appeared to lack information entirely on either the acquisition authority or the 

resolution of disagreements. 

Adding these specific fields to the IAA form would ensure that the agreements 

included the information required to adequately document the acquisition. 

40 48 C.F.R. § 17.503(b). 41 In addition, several D&F documents actually included information that was not required by FAR 17.503, 

such as the estimated cost of the IAA, sufficient funding availability and the legal authority for the IAA. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Treasury Financial Manual Guidance. The Department of the Treasury and 

OMB have both issued guidance covering IAA documentation. The Department 

of the Treasury issued TFM Bulletin No. 2007-03, “Intra governmental Business 

Rules,” which became effective on October 1, 2006. OMB’s guidance on 

interagency acquisitions became effective in part in October 2008 and in part in 

November 2008.42 The TFM bulletin includes documentation requirements for 

intra-governmental agreements or orders as shown in Table 1, below. 

 Table 1: Intragovernmental Business Rules, Procurement 

 Requirements for Intragovernmental Agreement/Orders 

Requirements 

• The agreement number and the funding source. 

• The Treasury Account Symbol for the ordering and servicing 

agencies. 

• The Business Event Type Code for the ordering and servicing 

agencies. 

• The effective date and duration of the agreement, including the 

expiration of the funding source. 

• The amount of the IAA and the method of payment. 

• The Business Partner Network number for the ordering and 

servicing agencies. 

• The method and frequency of performance reporting. 

• Provisions for advance payment and method for liquidating. 

advances, if applicable. 

• The parties’ rights to modify, cancel or terminate the agreement. 

• An alternative dispute resolution clause. 

• A clause specifying that if the ordering agency cancels the order, 

the seller is authorized to collect costs incurred prior to cancellation 

plus any termination costs. 

• Accounting/finance office, contracting officer/contracting officer’s 

technical representative point of contact information, such as name, 

location and telephone number. 

 Source: Treasury Financial Manual Bulletin No. 2007-03. 

The information described in Table 1 above, is intended to facilitate the 

reconciliation of accounts between ordering and servicing agencies.43 However, 

we found that the SECIAA/A form did not contain the following TFM bulletin 

requirements: Business Event Type Code, Business Partner Network Number, or 

 

42 OFPP requirements for “best interest determinations” went into effect on October 1, 2008. 

Implementation of the elements and model agreement contained in Appendices 2 and 3 to the OFPP 

guidance applied to IAAs entered into on or after November 3, 2008. Memorandum for Chief Acquisition 

Officers, Senior Procurement Executives, from Paul A. Dennet, Administrator, Office of Management and 

Budget, subject: Improving the Management and Use of Interagency Acquisitions, June 6, 2008. 

43 Department of the Treasury, Treasury Financial Manual Bulletin No. 2007-03, effective October 1, 2006. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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the method of performance reporting. The absence of this information could 

make it more difficult to record and reconcile the SEC’s IAAs according to the 

TFM bulletin requirements. 

Office of Management and Budget Guidance. OMB’s OFPP issued guidance 

on “Interagency Acquisitions” in June 2008. The guidance requires specified 

documentation of IAAs for assisted acquisitions that were entered into on, or 

after November 3, 2008.44 According to the guidance, IAA documentation serves 

the following two purposes: 

(1) To establish the general terms and conditions governing 

the relationship between the requesting and servicing 

agencies; and 

(2) To provide the information needed to establish a bona 

fide need and authorize the transfer and obligation of 

funds.

45

The OFPP also provides guidance in developing interagency agreement 

documentation. The guidance indicates that IAAs for assisted acquisitions 

should have two main parts, Part A and Part B. Part A includes the general 

terms and conditions that govern the responsibilities and roles of the requesting 

and servicing agencies.46 For example, Part A specifically requires identifying 

the legal authority for the interagency acquisition, and the period of 

performance.47 Part B requires “specific information on the requesting agency’s 

requirements sufficient to demonstrate a bona fide need.”48 The information 

required by Part B specifically includes projected milestones, fees, and the 

expiration date of the appropriation from which the funds are provided for the 

interagency acquisition.49 OFPP requires agencies to review their IAAs for 

assisted acquisitions carefully in conjunction with the guidance “to ensure they 

are clear and complete.”50 Further, OFPP encourages agencies to use the 

model IAA document in its guidance and, at a minimum, ensure that requires that 

their IAAs contain the elements enumerated in Appendix 2 to the guidance.51 

44 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy “Interagency Acquisitions,” June 2008, Appendices 2 and 3 at pgs. 32-46. 

45 Id. at p. 8. The term, “Bona fide need” refers to the availability of appropriated funds only for the 

payment of expenses properly incurred during the period of availability of the appropriation. See 31 U.S.C. 

§ 502(a). 

46 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy, “Interagency Acquisitions.” June 2008 at p. 8. 47 Id., Appendix 2 at p. 32 48 Id. at p. 8 (emphasis omitted). 49 Id., Appendix 2 at p. 35. 50 Id. Appendix 2 at p. 9. 51 Id. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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Our audit found that the SEC’s IAA documentation was not consistent with the 

format recommended by OFPP. The information contained in OFPP’s 

enumerated elements was also not readily found in the IAA documentation that 

we reviewed. In several instances, we had to review several documents (e.g., 

the IAA form, the terms and conditions, and the statement of work) to locate the 

required information. 

OA’s documentation of its IAAs requires updating to ensure that the D&F 

documents provide adequate justification for interagency acquisitions, and that 

required information for interagency acquisitions may be readily located. Also, 

OA should ensure that its IAA forms include information required to document the 

acquisition adequately in accordance with the OFPP guidance, and to facilitate 

recording and reconciling these agreements according to the TFM bulletin 

requirements. 

 

Recommendation 10: 

The Office of Acquisitions should update its interagency acquisition 

Determinations and Findings and interagency acquisition forms to include 

the information required by the Federal Acquisition Regulation, Treasury 

Financial Manual Bulletin No. 2007-03 (in consultation with the Office of 

Financial Management), and the Office of Federal Procurement Policy 

guidance on interagency acquisitions. 

Management Comments. Concur. See Appendix V for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurs with this 

recommendation. 

Finding 5: OA Lacked Adequate Information 

to Review IAA Cost Estimates 

OA did not know the basis for the cost estimates for 

the SEC’s IAAs with the U.S. Department of Health 

and Human Services’ Program Support Center/Mid 

Atlantic Cooperative Administrative Support Unit and 

the DOI’s National Business Center. Further, OA did 

not have adequate information to review these cost 

estimates for reasonableness. 

We judgmentally selected and carefully analyzed cost estimates for 2 of 133 

IAAs. Specifically, we reviewed IAAs for the Commission-wide administrative 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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support services provided by the U.S. Department of Health and Human 

Services’ Program Support Center (PSC)/Mid Atlantic Cooperative Administrative 

Support Unit (CASU) and the SEC’s employee payroll services provided by the 

DOI’s National Business Center (NBC). Both IAAs were not subject to the 

Economy Act, as they were authorized by statutes other than the Economy Act. 

The PSC funds its activities and services through a revolving fund52 that is 

authorized under the Government Management Reform Act of 1994. CASU is 

one of the PSC’s business units operated through the PSC’s Service and Supply 

Fund in accordance with 42 U.S.C. § 231. The DOI’s NBC provides payroll 

services to agencies through the DOI working capital fund established pursuant 

to 43 U.S.C. § 1467. 

Administrative Support Services IAA. The SEC entered into an IAA in August 

2008 for administrative support services through CASU, which consists of a 

network of vendors that provide goods and services to federal agencies. We 

reviewed a judgmental sample of 11 of 22 task orders that were issued on the 

CASU IAA. Our review of the CASU IAA included task orders for secretarial, 

paralegal, receptionist, and administrative assistant support positions at the SEC. 

According to OA’s listing of the CASU IAAs, the total cost of all the task orders 

under the CASU IAA was estimated to be $5 million. 

 

CASU documents its cost estimates for each task order on an “Estimate For 

Administrative Support Services” (Quote) form. The Quote form includes 

categories for labor, period of performance, number of hours, unit cost (the fully 

loaded hourly rate applied to a particular job title), and a total dollar amount. The 

quote is prepared as a result of a competitive proposal process managed by 

CASU from any of a group of small business contractors. The form also includes 

an employee hourly rate, which represents the wage rate to be paid to the 

employee and the minimum fringe benefit rate, which are different from the unit 

cost.53 The total estimated cost is calculated by multiplying the unit cost by the 

number of hours work needed. 

Our audit found that unit cost was significantly greater than the estimated hourly 

employee rate, plus the fringe rate. The OA contracting officer was unable to 

explain this disparity. After contacting the CASU representative, the contract 

52 A revolving fund is an account established to finance a continuing cycle of operations through amounts 

received, such as a working capital fund. See U.S. Government Accountability Office, Principles of Federal 

Appropriations Law, Third Edition, Volume III, GAO-08-978SP, September 2008 at pgs. 12-85 through 12-89 

for additional information on the concept and definition of revolving funds.

53 These rates are pursuant to the McNamara-O'Hara Services Contract Act of 1965, as amended, 41 

U.S.C. 351 et seq., which requires contractors and subcontractors performing services on covered federal 

contracts in excess of $2,500 to pay service employees in various classes no less than the monetary wage 

rates and fringe benefits found prevailing in the locality, or the rates contained in a predecessor contractor's 

collective bargaining agreement. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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specialist assigned to the IAA explained that the unit cost was higher than the 

employee hourly rate, plus the fringe rate, because a fee was included in the 

amount the SEC pays to CASU. This fee represents the difference between the 

unit cost and the employee’s hourly rate, plus the fringe rate and actually 

consists of two parts: a fee that the SEC pays CASU to provide contract 

administrative services; and the cost of services, overhead, and general and 

administrative expenses, as well as profit that CASU pays to the vendor. We 

found, however that the Quote form did not reflect this additional fee. OA staff 

did not have information to support the additional costs. It was only after OIG 

inquired about the estimates that OA staff requested detailed support for the 

figures. 

We calculated both components of the fee the SEC paid to CASU for the task 

orders identified in our sample based on the explanation provided by the OA 

contract specialist. We found that the SEC was paying a fee of $281,000 to 

CASU for the task orders in our sample, which represented the difference 

between what the employees were paid in wages and benefits and what CASU 

received. Hence, this amount was in addition to the employee hourly rate, plus 

the fringe costs, which amounted to $771,000. The $281,000 represented 

approximately 27 percent of the $1,052,000 total cost that was paid to CASU. 

When compared to the fee rates for other SEC IAAs that on average were 5 

percent,54 we found that 27 percent paid to CASU was significantly higher.55 

We further compared CASU’s rates to other vendors’ fee rates and judgmentally 

selected 15 of 269 small business contractors listed on the General Services 

Administration (GSA) schedules that provide administrative support and financial 

audit services. We found that 9 of the 15 small business contractors in our 

review listed lower rates than CASU in at least one labor category. Therefore, 

we have questions about the process that OA utilizes in choosing to enter into an 

IAA with CASU. OA should have undertaken a comparison of CASU’s costs to 

those of other vendors that provide similar services before entering into the 

agreement with CASU to ensure the government receives the best value. 

Cost Estimates for Payroll Services. In November 2006, OHR entered into an 

IAA with the DOI’s National Business Center for services related to processing 

payroll and personnel actions. The agreement was for FY 2007 and had a period 

of performance of one year. In March 2008, the SEC entered into its second IAA 

54 We calculated the 5 percent average fee based upon our review of the SEC’s IAAs with the Department of 

Justice (paralegal services), the Department of Transportation (transit subsidy) and the Office of Personnel 

Management (training management and assistance). 

55 While OA and CASU stated that of the 27 percent that the SEC pays to CASU, only 5 percent represents 

the contract administration fee, our audit found that on its face, the 27 percent is high and OA lacked 

adequate information to make a determination as to whether these costs were reasonable. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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with DOI for FY 2008. The IAAs cited the Economy Act56 and 43 U.S.C. §§ 1467 

and 1468 as the authorities for the agreements. We found that OA ratified the 

first six months of the FY 2008 IAA for approximately $420,000, because OHR 

had not timely submitted an IAA.57

The cost estimates for the IAAs with DOI were primarily based on the “HR 

Application Services Personnel and Payroll Operations” section of the SOW. 

These services included payroll operations, leave and earnings statements, and 

services provided through “Employee Express,” an on-line personnel system that 

is made available to SEC employees. When we asked OA staff about DOI’s cost 

estimate for the IAA, they indicated that they did not know how DOI came up with 

the number of W-2s that were used to calculate the cost estimate. Our audit 

determined that DOI used the total number of SEC W-2s that it processed two 

years earlier in calculating its cost estimate. For example, DOI used the number 

of W-2s processed in calendar year 2005 to develop the fiscal year 2007 

estimate. We found that OA does not require the customer to compare the W-2 

estimates DOI uses in its cost calculations to the actual number of W-2s to 

evaluate the reasonableness of DOI’s estimates and ensure that the cost 

estimates are accurate. 

According to the Federal Acquisitions Institute, OMB requires ordering agencies, 

such as the SEC in this situation, to provide input to the servicing agency to 

assist in the determination of whether proposed contract prices are fair and 

reasonable. The reasonableness of access or service fees charged by the 

servicing agency should be evaluated by the requesting agency as part of its 

"best interest determination."58 The OFPP guidance provides that in choosing an 

appropriate servicing agency, the requesting agency should give consideration to 

the “reasonableness of the servicing agency’s fees.”59

Our audit found that in connection with the IAA for DOI payroll services, OA failed 

to provide this input to ensure that the proposed contract prices were fair and 

reasonable. 

56 As noted above, the Economy Act was cited as authority in error as this IAA was not subject to the 

Economy Act. 

57 In September 2007, the OIG issued an inspection report addressing the issue of ratifications and 

recommended steps to improve controls in that area. See “Contract Ratifications,” Report No. 430, 

September 25, 2007. As of the date that the FY 2008 IAA was signed, OA had not implemented all OIG’s 

report recommendations. Currently, all but two of the report’s recommendations have now been 

implemented and are closed. 

58 The Federal Acquisitions Institute, “Interagency Acquisitions Roles and Responsibilities Reference Tool, 

”www.fai.gov/IAA/rrrt/rrrt.asp, Item 9. “Ensure price reasonableness.” 

59 Executive Office of the President, Office of Management and Budget, Office of Federal Procurement 

Policy, “Interagency Acquisitions,” June 2008 at pgs. 6-7. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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Homeland Security Presidential Directive-12 IAA. During our review of the FY 

2008 DOI estimate for payroll services, we noted that DOI reduced its estimated 

costs by $50,000 for services that the SEC did not receive from DOI under a 

separate IAA. In determining the source of the $50,000 credit, we learned that in 

July 2005, the SEC entered into an Economy Act IAA with DOI and advanced 

DOI $50,000 to provide needed support regarding the implementation of the 

Homeland Security Presidential Directive 12 (HSPD-12) badge requirements. 

The period of performance for the IAA was from July 2005 to July 2006. In 

September 2006, the SEC cancelled its IAA with DOI for HSPD-12 

implementation because DOI could not perform the services that were needed in 

the required timeframe. At the time the IAA was cancelled, DOI had not provided 

any services to the SEC under the IAA. However, the SEC did not require that 

DOI return the $50,000 the SEC had advanced to DOI for the IAA. Instead, DOI 

issued the SEC a $50,000 credit that was later applied as a reduction to the cost 

estimate for the SEC’s FY 2008 IAA for payroll services. 

Under the Economy Act, the funding advanced to DOI under the HSPD-12 IAA 

should have been returned to the SEC.60 Moreover, had OA reviewed the DOI 

cost estimates for 2008 payroll services, it would have learned of the $50,000 

credit and could have taken proper steps to retrieve the $50,000 that was 

advanced to DOI on the HSPD-12 IAA. 

 

Recommendation 11: 

The Office of Acquisitions should develop and implement appropriate 

procedures to review interagency acquisition cost estimates to ensure 

they are reasonable and properly supported. 

Management Comments. Concur. See Appendix V for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurs with this 

recommendation. 

Recommendation 12: 

The Office of Acquisitions should assess the Mid-Atlantic Cooperative 

Administrative Support Unit (CASU) interagency agreement to determine if 

the costs incurred are reasonable and the CASU interagency acquisition 

agreement is in the best interest of the Commission. 

60 See, e.g., In re Economy Act Payments After Obligated Account is Closed, B-260993, 1996 U.S. Comp. 

Gen. LEXIS 318 (June 26, 1996); In re Bureau of Land Management – Disposition of Water Resources 

Council Appropriations Advanced Pursuant to the Economy Act, B-250411, 72 Comp. Gen. 120 (March 1, 

1993). 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Management Comments. Concur. See Appendix V for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurs with this 

recommendation. 

Recommendation 13: 

The Office of Acquisitions should consider sources of administrative 

support services that charge lower amounts if it determines that the MidAtlantic Cooperative Administrative Support Unit interagency agreement 

does not provide the best value to the Commission. 

Management Comments. Concur. See Appendix V for management’s 

full comments. 

OIG Analysis. We are pleased that OA concurs with this 

recommendation. 

Finding 6: OHR’s Statement of Work for Its 

Human Resources Management Assistance 

IAA Did Not Conform to OPM’s TMA Program 

Guidance 

OHR’s statement of work for its IAA for human 

resources management assistance with the Office of 

Personnel Management Training and Management 

Assistance (OPM/TMA) program did not specifically 

identify the required services or products. Also, OHR 

did not include information in the SOW that was 

specified in guidance issued in reference to 

OPM/TMA program. 

OPM’s Training and Management Assistance Program. Between FYs 2006 

and 2007, OHR transferred approximately $5.1 million into OPM/TMA program’s 

revolving fund on an IAA for human resources management assistance services. 

In August 2006, OHR made an initial transfer of $2 million to OPM/TMA under 

this IAA. Thereafter, the IAA was amended three times, and approximately $3.1 

million in additional funding was transferred to the OPM/TMA account, bringing 

the total amount transferred under this IAA to $5 million. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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The OPM/TMA program provides assistance to agencies in the areas of training 

and human capital management. The program also provides assistance for 

workforce planning and restructuring, process improvement, and performance 

and compensation systems. The TMA program provides agencies with access to 

its contracts with a number of private sector vendors with expertise in human 

capital management. 

Pursuant to the SEC’s IAA with OPM/TMA, the TMA program provides services 

to OHR by awarding task orders against its contracts. OHR staff identified 

OHR’s service requirements to OPM/TMA, which, in coordination with OHR, 

competed and selected vendors that best met OHR’s requirements. The 

OPM/TMA issues task orders for the required services and maintains funding 

received from external agencies in a revolving fund, which is used to pay for work 

done under the IAA. OPM/TMA charges a fee for its contracting services that is 

based on the agency’s balance in the OPM/TMA revolving fund. The assessed 

fee is initially determined at the time an interagency agreement is established. 

The agency obligates an amount to include the fee, which is transferred and 

placed in the OPM/TMA revolving fund under the agency’s project code. 

OPM/TMA uses the revolving fund to pay contractors for their services on behalf 

of the agency. The assessed fee is collected only after the customer has 

approved a contractor invoice for the project task for payment 

Agencies enter into IAAs with the OPM/TMA under the authority of the 

Government Employees Training Act, the OPM revolving fund authority,61 and 

Executive Order 11348. The Economy Act does not apply to these types of 

IAAs. 

The OPM/TMA program guidance, posted on OPM’s website,62 describes a sixstep process as shown in Table 2 below, for agencies to follow when entering 

into an IAA with OPM/TMA. 

 

 

61 5 U.S.C. § 1304(e)(1). 62 U.S. Office of Personnel Monument, Training and Management Assistance: The Process, 

www.opm.gov/hrd/tma/theprocess.asp?1. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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 Table 2: OPM/TMA Program Interagency Agreement Guidance 

 Steps 

Interagency Agreement Steps 

1. Develop a Statement of Objectives (SOO) - The SOO provides a 

clear and concise description of the customer agency’s needs and 

expectations. It includes background information, the target audience 

for the goods and services, requirements, deliverables to be 

produced, specifications, and time frames. 

2. IAA - The IAA documents the terms and conditions of the relationship 

between the agency and the TMA program, obligates the agency’s 

funding and transfers it to TMA’s revolving fund. 

3. Task Order Competition – TMA selects a few pre-qualified contractors 

for the project described in the SOO. The contractors each present 

their capabilities and technical approaches to a panel composed of 

TMA and agency representatives. The panel evaluates the 

contractors, and TMA notifies the winning contractor. 

4. Project Kick-Off Meeting – TMA and agency representatives meet 

with the winning contractor to clarify project goals and expectations. 

5. Management Plan – The contractor, based on the discussions in the 

kick-off meeting, prepares a management plan including the tasks, 

activities, costs, and timelines to complete the project. 

6. Project Monitoring – The contractor begins work on the project. TMA 

issues work orders under the management plan, processes invoices, 

monitors spending, etc. 

 Source: OPM TMA Website 

Interagency Agreement for Human Resources Management Assistance. In 

August 2006, OHR entered into an IAA for $2 million with OPM/TMA to obtain 

human resources management assistance for its staff. The IAA consisted of a 

SOW that OHR included with its funding request. The IAA’s period of 

performance was from October 2006 to September 2007, and the IAA was an 

assisted acquisition, pursuant to which OPM staff served as the contracting 

officer for the IAA. Between September 2006 and September 2007, according to 

OHR, approximately an additional $3.1 million was transferred to the OPM/TMA 

account for the IAAs so the SEC could “lock in” a lower, more favorable fee rate. 

Transfer of Funds to the TMA Account. In June 2006, OHR requested that $2 

million be immediately transferred from its operating fund to the OPM/TMA 

program account.63 In that request, OHR staff indicated that TMA officials had 

informed them that TMA’s fee schedule would change in October 2006 and the 

 

63 Decision Memorandum to Acting Executive Director from Assistant Director, Office of Human Resources, 

Subject: Transfer of Funds, dated June 13, 2006. 
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fee rates would vary based on each agency’s fund balance.64 The request also 

stated that the OPM/TMA accounts provided a useful and flexible “no-year” 

contracting vehicle.65 OHR officials determined that it would be beneficial for the 

agency to “lock in” a 6 percent fee, by transferring a portion of OHR’s existing 

operating funds to the OPM/TMA revolving fund account.66 OHR officials further 

determined that transferring the funds at that time would ensure that OHR could 

have continued access to these funds by having them already available at 

OPM/TMA for contractors’ services as needed.67 In addition, OHR 

recommended that its Leadership and Knowledge Management Branch continue 

to monitor its budget and, in early September 2006 transferred additional funds to 

the OPM/TMA account.68 OHR transferred $2 million to TMA in August 2006, an 

additional $660,000 in September 2006, and approximately $2.4 million in 

September 2007. OHR indicated that it expected that maintaining a significant 

balance with OPM/TMA would allow the agency to reduce its fee to 5 percent.69 

OHR’s SOW Omitted Pertinent Information Included in the TMA Statement 

of Objectives Guidance. The OPM/TMA program provides written guidance on 

the information that agencies should submit to transfer funds to OPM/TMA. 

According to the guidance, the SOO should clearly and concisely describe the 

agency’s needs and expectations.70 Although the OPM/TMA guidance 

specifically described the information that should typically be included in the 

SOO, we found that OHR’s SOW71 for the IAA with OPM/TMA did not include 

much of the necessary information and did not even specify the services or 

products requested. The OPM/TMA guidance consists of information that should 

be included in the various SOO sections. Below we identify the information that 

is required for the various SOO sections and then contrast it with the information 

that was provided in OHR’s SOW. 

Background Section 

According to the OPM written guidance, the “Background” section of the SOO is 

to include an overview of the project and a description of circumstances that may 

affect the outcome of the project and the environment in which the services or 

64 Id. 65 “No-year” funding is generally available until expended and it does not become unavailable for obligation 

at the end of a fiscal year or a specific number of fiscal years. 66 Decision Memorandum to Acting Executive Director from Assistant Director, Office of Human Resources, 

Subject: Transfer of Funds, dated June 13, 2006. 

67 Id. 68 Id. 69 Id. 70 U.S. Office of Personnel Monument, Training and Management Assistance: The Process, Step1: 

Develop a Statement of Objectives, www.opm.gov/hrd/tma/theprocess.asp?1 71 The SEC’s document was called a “Statement of Work” and not a “Statement of Objectives.” 
Management and Oversight of IAAs at the SEC March 26, 2010 

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products will be used.72 In this instance, OHR never issued an SOO and the 

“Background” section of OHR’s SOW did not include any of the above required 

information. Instead, the background section briefly described the SEC’s 

mission, jurisdiction, and organizational structure. 

Audience Section 

According to the OPM written guidance, the “Audience” section of the SOO 

should describe the intended target audience of the services or products that are 

being sought.73 OHR’s SOW makes no mention of target audience for the 

products or services. 

Requirements Section 

The “Requirements” section of the SOO is referenced in the OPM written 

guidance as identifying the project objectives to be met and the link to the 

agency’s overall strategic and/or performance goals and the work or tasks to be 

performed.74 The “Requirements” section of OHR’s SOW did not refer to any 

specific projects. Instead, it included high-level descriptions of requirements for 

functions described as “Training, Learning, and Knowledge Management,” and 

“Strategic Human Resource Management Requirements.” Each function also 

included high-level descriptions of analysis, design, development, 

implementation and evaluation requirements.75 There was no discussion of the 

specific project objectives that were to be met, the links to agency strategic or 

performance goals, or to the specific work or tasks to be performed. In fact, 

OHR’s SOW specifically stated, “Individual project requirements will each be 

defined in separate Statements of Objectives.”76 

Deliverables Section 

According to the OPM written guidance, the “Deliverables” section is to consist of 

a description of the project’s outcomes or products be produced and the format in 

which they should be delivered.77 OHR’s SOW did not contain a description of 

the specific project outcomes or the products to be produced. Instead, the SOW 

72 U.S. Office of Personnel Monument, Training and Management Assistance: The Process, Step1: 

Develop a Statement of Objectives, www.opm.gov/hrd/tma/theprocess.asp?1 73 Id. 74 Id. 75 Statement of Work for an Inter-Agency Agreement between the SEC OHR and OPM TMA, “Analysis, 

Design, Development, Implementation ,and Evaluation of Customized Training, Learning, Knowledge 

Management, and Strategic Human Resource Management Interventions to Support and Improve Human 

Capital and Enterprise Performance (“OHR SOW”) at pgs. 2-12. 76 Id. at p. 2. 77 U.S. Office of Personnel Management Training and Management Assistance: The Process, Step 1: 

Develop a Statement of Objectives, www.opm.gov/hrd/tma/the_process.asp?1. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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stated that the selected contractor would propose specific deliverables for 

assigned project requirements; draft and final versions of each deliverable would 

be submitted; and all deliverables were to be developed using the latest SECapproved version of the “Microsoft Office Tool Suite,” unless otherwise 

directed.78 

Specifications Section 

According to the OPM written guidance, the “Specifications” section of the SOO 

identifies standards that products must meet, such as computer platform, 

software requirements and continuing education standards.79 The 

“Specifications” section of OHR’s SOW did not include the information that was 

described in the TMA’s SOO “Specifications” section. OHR’s specification 

section was general and vague, stated that systematic approaches to the training 

program’s design and development, and best professional and industry practices 

would be utilized for all the work conducted under the contract. It further 

indicated that the SEC’s specifications would be in force during the conduct of 

projected work, where applicable.80 

Time Frames 

The OPM written guidance provided for inclusion in the SOO of critical project 

dates, such as the Estimated Start Date, Critical Interim Dates, and Desired 

Completion Date.81 However, OHR’s SOW did not include any of these dates. 

Instead, it simply contained a “Period of Performance” section, which indicated 

that individual projects conducted under the agreement would be initiated the 

within the timeframes established by SEC management and that separate, 

detailed schedules and timelines would be developed for individual projects 

initiated under the agreement.82

Contact with OPM TMA Officials. In October and November 2009, the OIG 

spoke with OPM/TMA program officials regarding the program, the written 

guidance and the specifically the requirements for a SOO. OPM/TMA program 

officials stated the written guidance is not binding and there is some flexibility 

with respect to the information that is to be included in the SOO. Yet, these 

officials acknowledged that OPM/TMA issued guidance for agencies to use so 

that sufficient information is included in their SOOs. 

78 OHR SOW at p.12. 79 U.S. Office of Personnel Management Training and Management Assistance: The Process, Step 1: 

Develop a Statement of Objectives, www.opmg.gov/hrd/tma/the_process.asp?1. 80 OHR SOW at p. 13. 81 U.S. Office of Personnel Management Training and Management Assistance: The Process, Step 1: 

Develop a Statement of Objectives, www.opmg.gov/hrd/tma/the_process.asp?1. 82 OHR SOW at p. 12. 
Management and Oversight of IAAs at the SEC March 26, 2010 

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While we understand that the written OPM guidance does not have the force and 

effect of law, and the OPM/TMA program may not require strict adherence to the 

its guidance, we determined that OHR’s SOW failed to include so much critical 

information included in the written guidance that the matter should be addressed. 

Recommendation 14: 

The Office of Acquisitions should provide additional training to its 

contracting staff and customers regarding interagency acquisitions. 

This training should include developing and ensuring the adequacy 

of statements of work and statements of objectives according to 

applicable guidance and requirements. 

Management Comments. Nonconcur. See Appendix V for 

management’s full comments. 

OIG Analysis. We do not agree with OA’s response to this 

recommendation. OA develops acquisition related policies and 

procedures for the Commission and is in a position to assist its customers 

in ensuring their requirements as identified in statements of work and 

statements of objectives, etc., meet the applicable acquisition-related 

requirements. See Appendix VI for OIG’s full response to management’s 

comments. 

Recommendation 15: 

The Office of Human Resources, in consultation with the Office of 

Acquisitions, should ensure that future Memoranda of 

Understanding provide appropriate specificity with regard to the 

types of products and services required, in accordance with 

applicable requirements. 

Management Comments. Concur. See Appendix V for management’s 

full comments. 

OIG Analysis. We are pleased that OHR and OA concurs with this 

recommendation. 
Appendix I 

Acronyms

CASU Cooperative Administrative Support Unit 

COTR Contracting Officer’s Technical Representative 

D&F Determination and Finding 

DOI Department of Interior 

FAR Federal Acquisition Regulation 

FY Fiscal Year 

GAO Government Accountability Office 

GSA General Services Administration 

IAA Interagency Acquisition Agreement 

IPAC Intra-Governmental Payment and Collection system 

NBC National Business Center 

OA Office of Acquisitions 

OAPM Office of Administrative and Personnel Management 

OAS Office of Administrative Services 

OFM Office of Financial Management 

OFPP Office of Federal Procurement Policy 

OHR Office of Human Resources 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

PSC Program Support Center 

SEC or Commission U.S. Securities and Exchange Commission 

SOO Statement of Objectives 

SOW Statement of Work 

TFM Treasury Financial Manual 

TMA Training and Management Assistance Program 

Management and Oversight of IAAs at the SEC March 26, 2010 

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Appendix II 

Scope and Methodology

We conducted this performance audit in accordance with generally accepted 

government auditing standards. These 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. 

Scope. The scope of the audit included interagency acquisitions of goods and 

services by the SEC from other federal agencies. We reviewed judgmental 

samples from interagency acquisitions awarded between FY 2007 and 2009 and 

interagency acquisitions that were open during that time period. We also 

reviewed information from the Momentum financial system as it related to 

interagency acquisitions. We conducted our fieldwork between April and August 

2009. 

We did not review interagency transactions involving reimbursable use of SEC 

staff at other agencies or assistance provided by the SEC to other entities. We 

also did not review data from the OA’s PRISM acquisition database system 

because OA staff indicated that the system did not include information regarding 

interagency acquisitions. 

Methodology. To meet the object to assess compliance with governing federal 

and Commission regulations and polices, OIG obtained and reviewed laws, 

regulations, policies and procedures regarding interagency acquisitions. We 

further interviewed staff in OA, OFM and certain SEC program offices in order to 

evaluate the SEC’s processes and procedures to approve, obtain, monitor, and 

close IAAs. 

Also, we contacted staff at the Department of Health and Human Services and 

DOI to discuss the cost estimates they provided to the SEC. In addition, we 

surveyed all the SEC offices and divisions to determine whether they awarded 

their own IAAs independent of OA. None of the SEC offices and divisions 

indicated that they awarded IAAs independent of OA. 

Management and Oversight of IAAs at the SEC March 26, 2010 

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To meet the objective to determine whether opportunities exist for the SEC to 

save costs associated with IAAs, we judgmentally selected samples of IAAs to 

review from a list of 133 IAAs OA provided to the OIG. We reviewed the 

documentation in the selected IAA files and analyzed the information contained 

therein. We compared the information in from the IAA list to the IAA file 
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documentation, IAA documentation that OA maintained on its shared drive, and 

financial information regarding IAAs in the Momentum system. 

Management Controls. We reviewed controls that were considered significant 

within the context of the audit objectives. We interviewed management and staff 

from OA and other organizations, identified and reviewed applicable policies and 

procedures, obtained and reviewed IAAs, and tested the data for compliance with 

selected policies and procedures. We identified areas for improvement in 

management controls over IAAs. 

Use of Computer-Processed Data. We used interagency acquisition data 

maintained by OA on spreadsheets. Also, we used data from the Commission’s 

financial system, Momentum. We did not perform extensive tests of system 

general or application controls on the Momentum system because it was not an 

audit objective or sub-objective. To the extent practical, however, we compared 

the IAA data we received with the IAA source documents in the files and with 

data from Momentum. We found discrepancies in the IAA data that we received 

from OA, including missing and incorrect IAA data. 

Judgmental Sampling. We selected judgmental samples of IAAs that were 

awarded or open between FY 2007 and 2009 to review. Specifically, to evaluate 

compliance with the FAR we reviewed D&Fs from a judgmental sample of 13 of 

133 IAAs. Of the 13 IAAs selected for review, 4 were covered by the Economy 

Act, and 9 were non-Economy Act acquisitions. Also, 5 of 13 IAAs were assisted 

acquisitions, while 8 were direct acquisitions. Further, we judgmentally selected 

21 IAAs from our population of 133 IAAs and found that 10 of the 21 selected 

IAAs were prepared on the SEC’s award forms, while the remaining 11 IAAs 

were prepared on the other agencies’ forms. We then judgmentally selected and 

carefully analyzed 2 of the 133 IAA’s cost estimates. Our review also included a 

judgmental sample of 15 of 269 small business contractors from the GSA 

schedules that provides administrative support to agencies. 

Our findings applied to the items reviewed and were not extrapolated to the 

universe from which our samples were obtained. 

 

High-Risk Areas. GAO identified interagency acquisitions as a high-risk area in 

2005.83 GAO indicated that its work and that of the agencies’ inspectors general 

had identified instances where interagency acquisitions were improperly used.84 

The identified causes of these deficiencies included increasing demands on 

acquisition staff, insufficient training and inadequate guidance.85 GAO again 

83 U.S. Government Accountability Office, “High-Risk Series: An Update,” GAO-05-207, January 2005. 84 Id. at p. 26. 85 Id. at p. 27. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 36 

 

identified interagency acquisitions as a high-risk area in 2009, though it noted 

improvements have been made since 2005.86

Prior Audit Coverage. Our office, GAO and other inspector general offices 

issued reports regarding various aspects of interagency acquisitions as follows: 

• “Interagency Agreements,” Report No. 228, issued by SEC/OIG, February 

1, 1996. 

• “Interagency Agreements to Use Other Agencies’ Contracts Need 

Additional Oversight,” Report No. 2007-P-00011, issued by U.S. 

Environmental Protection Agency/OIG, March 27, 2007. 

• “Interagency Contracting: Need For Improved Information and Policy 

Implementation at the Department of State,” Report No. GAO-08-578, 

issued by GAO, May 2008. 

• “Disbursing Operations Directorate at Defense Finance and Accounting 

Service Indianapolis Operations,” Report No. D-2008-052, issued by 

Department of Defense/OIG, February 19, 2008. 

86 U.S. Government Accountability Office, “HIGH-RISK SERIES: An Update,” GAO-09-271, January 2009, at 

p. 79. 
Appendix III 

Criteria 

The Economy Act, 31 U.S.C. §§ 1535, 1536. The Economy Act provides 

general authorization for agencies to place orders for goods or services with 

other agencies if: amounts are available; the order is in the U.S. Government’s 

best interest; the agency filling the order can provide the goods and services or 

obtain them by contract; and the requesting agency cannot obtain the goods or 

services more cheaply or conveniently from a commercial enterprise. The 

Economy Act does not apply if a more specific authorization for a particular 

interagency acquisition exists. 

The Recording Statute, 31 U.S.C §1501(a). This statute requires that the 

obligation of federal funds shall be supported by documentation of a binding 

agreement between the agency and another person (including another agency) 

for specific goods to be delivered, real property to be purchased or leased, or 

services to be provided. 

Federal Acquisition Regulation Subpart 17.5, Interagency Acquisitions 

Under the Economy Act (48 C.F.R. §§ 17.500-17.505). This Subpart contains 

policies and procedures applicable to interagency acquisitions under the 

Economy Act. Specifically, among other things, it requires: Determinations and 

Findings documenting that the interagency acquisition meets the requirements in 

the Economy Act, identifies the information required to be included in an 

Economy Act order for supplies or services with another government agency, 

and prohibits payments of fees or changes in excess of actual or estimated costs 

on IAAs that requires the use of a contract by the servicing agency. 

Government Accountability Office Principles of Federal Appropriations Law 

(Red Book), Third Edition, Volume II, February 2006, and Volume III, 

September 2008. These volumes serve as a detailed fiscal law guide covering 

those areas of law in which the Comptroller General renders decisions, and 

describes existing legal authorities to illustrate, the principles discussed, their 

application, and exceptions thereto. 

Treasury Financial Manual Bulletin No. 2007-03, “Intragovernmental 

Business Rules,” Effective October 1, 2006. This bulletin provides guidance 

to federal agencies for recording and reconciling intragovernmental exchange 

transactions, including interagency acquisitions. 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 37 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 38 

Appendix III (Cont.) 

“Interagency Acquisitions,” Executive Office of the President, Office of 

Management and Budget, Office of Federal Procurement Policy, June 2008. 

This guidance is intended to help agencies achieve the greatest value possible 

from interagency acquisitions, wherein a requesting agency uses the contracts or 

contracting services of a servicing agency to obtain supplies and services. It 

does not address all interagency business transactions, but only those 

undertaken for the primary purposes of obtaining services or products from 

contractors. 

Office of Personnel Management Training and Management Assistance 

(TMA) Program Process Guidance. This guidance provides federal agencies 

with a six-step process for obtaining training and human capital solutions through 

the TMA reimbursable program, including the development of a statement of 

objectives. 

SEC Regulation 10-2, SEC Contracting Authorities and Appointments, June 

24, 2008. Establishes uniform policies and procedures for the acquisition of 

products and services for the SEC. 

SEC Regulation 10-14, Contract Administration, April 28, 2005. Establishes 

the Commission’s contract closeout program and explains how it functions and 

implements various FAR provisions. States that it applies to all contracts and 

Economy Act acquisitions. 
Appendix IV 

List of Recommendations 

Recommendation 1:

The Office of Acquisitions (OA), in coordination with the Office of Financial 

Management (OFM), should identify its universe of open interagency 

acquisitions and the corresponding amounts obligated and expended on each 

interagency acquisition. Once this is accomplished, OA should reconcile its 

universe of active and open interagency acquisitions with the financial 

information maintained by OFM regarding active and open interagency 

acquisitions and the corresponding amounts obligated and expended. 

Recommendation 2:

The Office of Acquisitions should maintain its interagency acquisition data in 

the appropriate centralized automated system to ensure appropriate access 

to and accuracy of data and to provide for report generation capabilities. 

Recommendation 3:

The Office of Acquisitions should establish appropriate internal controls to 

provide reasonable assurance that, in the future, interagency acquisition 

agreement data is accurate, timely, complete and reliable. 

Recommendation 4: 

The Office of Acquisitions should develop internal written policies and 

procedures to guide it in administering interagency acquisitions. These 

policies and procedures should be based on appropriate risk assessments, 

address both Economy Act and Non-Economy Act acquisitions, and 

incorporate Federal Acquisition Regulation Subpart 17.5, the Office of Federal 

Procurement Policy’s guidance on interagency acquisitions, and other 

requirements regarding interagency acquisitions as appropriate. 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 39 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 40 

Recommendation 5: 

In developing written policies and procedures for assisted interagency 

acquisitions the Office of Acquisitions should incorporate the requirements of 

the Economy Act, the Office of Federal Procurement Policy guidance on 

interagency acquisitions, and other controlling authorities, and coordinate 

with the Office of Financial Management to assure its minimum requirements 

are also included. The Office of Acquisitions should ensure that its written 

policies and procedures for interagency acquisitions include guidance on: 

• Ensuring that statements of work for interagency acquisitions related to 

assisted services meet the applicable requirements; 

• Ensuring the reasonableness of interagency acquisition costs; 

• Including the appropriate documents in interagency acquisition files; 

• Recording and maintaining complete information on interagency 

acquisitions; and 

• Closing expired interagency acquisitions. 

Recommendation 6:

The Office of Acquisitions should benchmark other federal agencies’ written 

policies and procedures for interagency acquisitions when developing its 

interagency acquisition agreement written policies and procedures. 

Recommendation 7:

The Office of Acquisitions should develop written policies and procedures 

regarding interagency acquisitions that include timeframes and procedures for 

closing out Economy Act and non-Economy Act interagency acquisitions and 

deobligating funds for both assisted and direct acquisitions. The closeout 

procedures should also identify the Commission’s process for coordinating 

with servicing agencies. 

Recommendation 8:

The Office of Acquisitions should promptly identify fully all interagency 

acquisition agreements that have expired and have not been closed. The 

Office of Acquisitions should further deobligate any funds that remain on the 

expired agreements. 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 41 

Recommendation 9: 

The Office of Acquisitions should take action to close the interagency 

acquisitions we identified for which the performance expired and deobligate 

the $6.9 million in unused funds that remain on the interagency acquisitions, 

in accordance with the appropriate close-out procedures. 

Recommendation 10: 

The Office of Acquisitions should update its interagency acquisition 

Determinations and Findings and interagency acquisition forms to include the 

information required by the Federal Acquisition Regulation, Treasury 

Financial Manual Bulletin No. 2007-03 (in consultation with the Office of 

Financial Management), and the Office of Federal Procurement Policy 

guidance on interagency acquisitions. 

Recommendation 11: 

The Office of Acquisitions should develop and implement appropriate 

procedures to review interagency acquisition cost estimates to ensure they 

are reasonable and properly supported. 

Recommendation 12: 

The Office of Acquisitions should assess the Mid-Atlantic Cooperative 

Administrative Support Unit (CASU) interagency agreement to determine if 

the costs incurred are reasonable and the CASU interagency acquisition 

agreement is in the best interest of the Commission. 

 

Recommendation 13: 

The Office of Acquisitions should consider sources of administrative support 

services that charge lower amounts if it determines that the Mid-Atlantic 

Cooperative Administrative Support Unit interagency agreement does not 

provide the best value to the Commission. 

Recommendation 14: 

The Office of Acquisitions should provide additional training to its contracting 

staff and customers regarding interagency acquisitions. This training should 

include developing and ensuring the adequacy of statements of work and 

statements of objectives according to applicable guidance and requirements.

 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 42 

Recommendation 15: 

The Office of Human Resources, in consultation with the Office of 

Acquisitions, should ensure that future Memoranda of Understanding provide 

appropriate specificity with regard to the types of products and services 

required, in accordance with applicable requirements. 
Appendix V 

Management Comments 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 43 

MEMORA DUM

March 12,2010

TO: H. David Kotz

Inspector General

Office ofInspector General (OIG)

FROM: haron Sheehan ft,,J.

Associate Director

Office of Administrative Services (OAS)

UBJECT: OIG Draft Audit ofManagement and Oversight of Interagency

Acquisition Agreements at the SEC, Report No. 460

Thank you for the opportunity to comment. OAS has begun taking appropriate steps to

address these recommendations. You will see that OAS non-concurs with

Recommendation 14, and concurs with all other recommendations.

Recommendation 1:

OAS concurs. OA is changing its operating procedures and developing a holistic

record-keeping system. OA recently deployed its new automatic procurement system

(PRI M), thus giving OA an automated system to facilitate a consolidated record of

active, pending, completed, modified, or cancelled contracts. PRISM is being deployed in

two phases, with the second phase creating a link between PRISM and OFM's

Momentum® financial ystem. This will allow both offices to track interagency

agreements (IAAs), and generate a consolidated list ofIAAs.

Recommendation 2:

OAS COnCur. Interagency acquisitions are now created in PRISM, which will soon

interface with Momentum . The interface, which contains key A- I 23 controls, will

aHow for accurate record keeping.

Recommendation 3:

OAS concurs. OA will develop appropriate guidance on IAAs for staff.

Recommendation 4:

OAS concurs. As discussed in our response to Recommendation 3, OA will develop

guidance on IAAs for staff.
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 44 

Recommendation 5:

QAS concurs.

Recommendation 6:

OAS concurs.

Finding3:

Although the servicing agency's contracting officer will close out the IAA. we will

improve our administration and work eollaboratively with the servicing agency to assure

IAA timely closeout.

Recommendation 7:

OAS concurs. OAS again requests that this recommendation be included as part of

Recommendation 4 with respect to issuing policy. The policy will reflect SEC suppon

for c1ose-oul functions ofthe servicing agency'S contnlCting officer.

Re<:ommendation 8:

OAS concurs. QA began consolidating lists of all open contracts and interagency

acquisitions in January 2010. OA will rely on the data generated by PRISM to track

expiration dates.

Recommendatioo 9:

OAS concurs. Once a complete list is validated, OA will begin scheduling expired

interagency acquisitions for reconciliation and will work with the servicing agency to

assure timely closeout.

Recommendation 10:

QAS concurs. As discussed in the comment to Recommendation 3, OA will develop

appropriate guidance on IAAs for staff.

Recommendation II:

OAS concurs. As discussed in the comment to Recommendation 3, OA will dcvelop

appropriatc guidance on IAAs for staff.

R«om.mendation 12:

OAS concurs. OA completed its analysis of tile Depanment ofHealth and Human

Service's Cooperative Administnltive Suppon Units (CASU) requests Recommendations

2
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 45 

12 and 13 be closed prior to final issuance ofthe audit. OA confinned with CASU that

the administrative fee is two percent. OA previously contracted with two other sources

for similar support without success. Their rates were high and talent was lacking. OA

will procure services in accordance with the FAR to obtain best value.

Reconimendllltion 13:

OAS concurs. As discussed in the comment to Recommendation 12. OA contacted

Depanmcnt of Heallh and Hwnan Servicc's CASU. which confinned thc set

administrative fee is two percent for all its Federal customers.

Recommendation 14:

OAS non-concurs with the responsibility for conducting Statement of Work training.

Developing adequate requirement statements. such as SOWs. SOOs. PWS·s. etc., is the

responsibility ofthe requiring activities. Training sources for documenting requirements

are readily available in the commercial market and online at "Acquisition Central"

www.acquisition.gov/sevenstepslhome.html.

Recommendation IS:

GAS concurs.

3
Appendix VI 

OIG Response to Management’s Comments 

We are pleased that OAS fully concurred with 14 of 15 recommendations 

pertaining to its office and OFM and OHR each concurred with the 

recommendation that related to its respective offices as well. We believe these 

recommendations will improve the Commission’s ability to manage interagency 

acquisitions, comply with mandated statues, regulations and guidance as they 

pertain to their management and oversight, and increase opportunities for cost 

savings. 

The OIG’s response to OAS’s non-concurrence to recommendation 14 is as 

follows. We believe that recommendation 14 which states that OA “should 

provide additional training to its contracting staff and customers regarding 

interagency acquisitions,” including developing and ensuring the adequacy of 

statements of work, may have been misinterpreted. In its management 

comments, OA states that: “Developing adequate requirement statements, such 

as statement of work, statement of objectives, performance work statements, 

etc., requirements documents is the responsibility of the requiring activities. 

Training sources for documenting requirements are readily available in the 

commercial market and online at ‘Acquisition Central’. . . .” 

We agree that the customer has responsibility for developing its own 

requirements and are not recommending that OA prepare requirements 

documents for customers. We also acknowledge that OA customers may obtain 

training from commercial vendors in developing requirements documents. 

However, since OA develops acquisition-related policies and procedures for the 

Commission, it is in a position to assist its customers in ensuring the requirement 

documents they prepare meet the applicable acquisition-related requirements. 

We found evidence in our audit that these requirements are not being met. OA is 

the only office within the Commission that has the expertise to ensure that 

customers obtain the knowledge necessary to meet the pertinent requirements. 

Thus, we believe that it would be useful for these customers and the Commission 

as a whole for OA to conduct this training. 

 

In addition, we note that since OA signs the IAA agreements that obligate 

funding, it is in OA’s interest to ensure that the related requirements adequately 

describe the goods and services that are requested in the statement of work and 

statement of objectives. Thus, we remain convinced that OA should further 

provide guidance to its customers to help them ensure the adequacy of 

statements of work and statements of objectives according to applicable 

guidance and requirements. 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 46 
Appendix VII 

Universe of IAAs Provided by OAS 

Table 3: Universe of the Commission’s IAAs OAS Provided to OIG 

Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

1. GSA Economy Act $156,825,306 $51,021,149 Sept 30, 2008 Expired 

2. OPM Economy Act $1,200,000 $1,931,327 Not Indicated Expired 

3. Treasury Not Indicated Not Indicated Not Indicated Not Indicated Expired 

4. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

5. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

6. FedLink 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

7. Treasury Not Indicated Not Indicated $83,292 Not Indicated Expired 

8. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

9. DOT 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

10. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

11. FOH 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

12. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

13. FOH 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

14. NARA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

15. NARA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

16. USPS 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

17. GAO 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

18. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

19. GSA Economy Act $12,732,185 $12,732,185 Oct 1, 2003 - 

Dec 14, 2009 

Open 

20. GSA Economy Act $1,359,170 $4,202,170 Sept 30, 2007 Expired 

21. FTC Economy Act $200,000 $45,000 Not Indicated Open 

22. GSA Economy Act $5,752,548 $5,752,548 Oct 1, 2004 - 

Sept 30, 2009 

Open 

23. GSA Economy Act Not Indicated $8,776,320 

Oct 1, 2004 - 

Sept 30, 2007 Expired 

24. GSA Economy Act $206,285 $206,285 

Oct 01, 2004 - 

Sept 27, 2005 

Expired 

Management and Oversight of IAAs at the SEC March 26, 2010 

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Page 47 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 48 

Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

25. Treasury Economy Act Not Indicated $38,827 Not Indicated Open 

26. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

27. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

28. Pacer 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

29. Treasury 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

30. FOH 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

31. DOT 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

32. NARA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

33. NARA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

34. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

35. FOH 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

36. DOI 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

37. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

38. DOI 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

39. Treasury 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

40. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

41. D.C. 

Treasurer 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

42. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

43. PCIE/ECIE 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

44. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

45. DOJ 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

46. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

47. DOI 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

48. GAO 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

49. DOI 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

50. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 49 

Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

51. UNICOR 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

52. UNICOR Economy Act $1,549,556 $1,549,480 

Sept 21, 2005- 

Sept 30, 2008 Expired 

53. DOT Economy Act $2,036,638 $2,036,638 

Oct 1, 2005 - 

Sep 30, 2006 Expired 

54. NARA Economy Act $276,500 $276,500 

Oct 01, 2006 - 

Sept 30, 2007 Expired 

55. NARA Economy Act $10,000 $10,000 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

56. PACER Economy Act $229,981 $229,981 Oct 1, 2005 - 

Sept 30, 2008 

Expired 

57. GSA Economy Act $27,750 $27,750 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

58. RTD 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

59. LOC Economy Act $7,499 $7,499 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

60. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

61. GSA Economy Act $32,248 $32,248 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

62. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

63. DOJ Economy Act $9,706,186 $9,706,186 

Oct 1, 2006 - 

Sept 30, 2007 Expired 

64. DOI - NBC Economy Act $842,534 $842,534 Not Indicated Open 

65. Treasury Economy Act $260,000 $260,000 Sept 30, 2006 Expired 

66. GAO Economy Act $1,000,000 $1,000,000 Feb 28, 2007 Expired 

67. FOH Economy Act $3,164,619 $2,758,050 

Oct 1, 2006 - 

Sept 30, 2009 Expired 

68. DOI Economy Act $122,650 $122,650 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

69. DOJ Economy Act $150,000 $98,550 July 31, 2007 Expired 

70. OPM Economy Act $19,092 $19,092 

Oct 1, 2006 - 

Aug 29, 2007 Expired 

71. OPM Economy Act $28,750 $28,750 

Oct 1, 2007 - 

Sept 30, 2007 Expired 

72. OPM-TMA Economy Act $5,055,700 $5,055,700 

Oct 1, 2006 - 

Sept 30, 2009 Open 

73. OPM Economy Act $200,000 $80,000 Not Indicated Open 

74. GOVWORK

S Economy Act 

Not Indicated Not Indicated Oct 1, 2006 - 

Sept 30, 2008 Expired 

75. GSA 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 50 

Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

76. FED EXE 

BOARD Economy Act $10,000 $10,000 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

77. GSA Economy Act $400,000 $400,000 Not Indicated Open 

78. LOC Economy Act $7,720 $7,720 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

79. DOT Economy Act $2,121,886 $2,121,886 Sept 30, 2007 Expired 

80. NARA Economy Act $286,380 $688,931 

Oct 1, 2005 - 

Sept 28, 2007 Expired 

81. NARA Economy Act Not Indicated $24,000 Not Indicated Open 

82. DOI - NBC Economy Act $926,356 $926,356 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

83. Treasury Economy Act $55,000 $55,000 

Dec 1, 2006 - 

Nov 30, 2007 Expired 

84. OPM Economy Act $906,528 $906,528 

Jan 1, 2004 - 

Dec 31, 2008 Expired 

85. DCAA Economy Act $19,981 $19,981 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

86. DOI Economy Act $120,800 $120,800 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

87. USDA Economy Act $500 $500 Apr 30, 2007 Expired 

88. LOC Economy Act $31,516 $31,516 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

89. GAO Economy Act $1,000,000 $1,000,000 

May 25, 2007 - 

May 24, 2008 Expired 

90. MACASU Economy Act $191,368 $191,368 

Apr 1, 2006 - 

Sept 30, 2008 Expired 

91. LOC Economy Act $27,853 $27,853 

Oct 1, 2006 - 

Sept 28, 2007 Expired 

92. GSA Economy Act $6,530,124 $7,771,824 Not Indicated Open 

93. GSA Economy Act Not Indicated $1,501,000 Not Indicated Open 

94. OPM Economy Act Not Indicated Not Indicated Not Indicated

Not 

Indicated

95. GSA Economy Act $22,500 0 Not Indicated Open 

96. DOS Economy Act $45,000 $45,000 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

97. DOJ Economy Act $91,925 $91,925 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

98. OPM Economy Act $56,371 $56,371 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

99. OPM Economy Act $33,800 $33,800 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

100. OPM Economy Act $5,437 $5,437 

Oct 1, 2007 - 

Sept 30, 2008 Expired 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

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Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

101. OPM Economy Act $5,000 $5,000 

Oct 1, 2006 - 

Sept 30, 2007 Expired 

102. DOT 

Not Indicated Not Indicated Not Indicated Not Indicated Not 

Indicated 

103. OPM Economy Act $845,500 $945,500 Not Indicated Open 

104. GSA Economy Act 

Not Indicated Not Indicated Not Indicated Not 

Indicated 

105. GSA Economy Act $11,940 $11,940 

Oct 1, 2007 – 

Sept 30, 2008 Expired 

106. DOT Economy Act $1,731,372 $1,731,372 

Oct 1, 2007 – 

Sept 30, 2008 Expired 

107. GSA Economy Act $55,000 $55,000 

Oct 1, 2007 – 

Sept 30, 2008 Expired 

108. DOI Economy Act $184,611 $184,611 

Oct 1, 2007 – 

Sept 30, 2008 Expired 

109. DOI Economy Act $855,394 $855,394 

Oct 1, 2007 - 

Mar 31, 2008 

Not 

Indicated 

110. GPO Economy Act $58,000 $58,000 

June 30, 2008 

- Sept 30, 

2009 Open 

111. MACASU Economy Act $5,000,000 $78,104 Jul 31, 2013 Open 

112. MACASU Economy Act $659,850 $437,224 

Aug 19, 2008 - 

Sept 30, 2009 Open 

113. OPM Economy Act $37,391 $37,391 

Aug 28, 2008 - 

Sept 30, 2009 Open 

114. LOC Economy Act $37,028 $37,028 

Oct 1, 2007 - 

Sept 30, 2008 Expired 

115. Treasury Economy Act $3,300 $3,300 

Mar 1, 2008 - 

Sept 30, 2008 Expired 

116. GSA Economy Act $3,056,513 $3,056,513 

June 30, 2008 

- Sept 30, 

2009 Open 

117. GAO Economy Act $1,768,696 $1,768,696 

Apr 25, 2008 - 

Apr 24, 2009 Expired 

118. DOJ Economy Act $10,000 $10,000 

May 28, 2007 - 

May 30, 2008 Expired 

119. DOE Economy Act $45,000 $45,000 

Oct 01, 2007 - 

Sept 30, 2008 Expired 

120. GPO Economy Act $35,000 $35,000 

July 1, 2008 - 

June 30, 2010 Open 

121. DOJ Economy Act $108,952 $108,952 

July 1, 2008 - 

June 30, 2009 Open 

122. DOS Economy Act $250,000 $50,000 Not Indicated Open 

123. OPM Not Indicated Not Indicated Not Indicated Not Indicated 

Not 

Indicated124. DOJ Economy Act $250,000 $50,000 Not Indicated Open 
M

R

anagement and Oversight of IAAs at the SEC March 26, 2010 

eport No. 460 

Page 52 

Name of 

Servicing 

Agency 

Authority for 

Interagency 

Agreement 

Total 

Cost 

Total 

Obligated 

Period of 

Performance 

Status: 

Open or 

Expired 

125. OCC Economy Act $53,282 $53,282 

Sept 1, 2008 - 

Sept 30, 2008 Expired 

Oct 1, 2008 - 

126. DOI Economy Act $1,149,446 $0 Sept 30, 2009 Open 

Nov 25, 2008 - 

127. GSA Economy Act $28,600 $28,600 Nov 24, 2009 Open 

128. DOT Economy Act $1,236,402 $1,236,402 Sept 30, 2009 Open 

Oct 1, 2008 - 

129. LOC Economy Act $763 $763 Sept 30, 2009 Open 

Oct 1, 2008 - 

130. DOE Economy Act $45,000 $45,000 Sept 30, 2009 Open 

Oct 1, 2009 - 

131. OPM Economy Act $367,893 $367,893 Sept 30, 2014 Open 

Jan 1, 2009 - 

132. Treasury Economy Act $12,500 $12,500 Sept 30, 2009 Open 

133. GAO Economy Act $1,300 $1,300 

Apr 20, 2009 - 

Apr 19, 2010 Open 

Total $233,791,514 $136,279,546 

Total Entries 176 

Total 

Amendments 9 

Total 

Duplicates 20 

Total Non-IAAs 14 

Total 

Adjustments 43 

Total Number 

Adjusted of IAAs 133 

Source: OIG Generated 
Appendix VIII 

Duplicates, Amendments, & Errors 

Table 4: Duplicates, Amendments, and Errors 

Name of 

Servicing 

Agency 

Authority 

for IAA 

Total Cost Total 

Obligated 

Period of 

Performance

Status: Open, 

Expired, 

Closed 

1. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

2. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

3. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

4. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

5. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

6. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

7. NARA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

8. MACASU 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

9. GAO 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

10. FEDSOURCE Economy 

Act $260,000 

Not Indicated Not Indicated

Open 

11. GAO 

Economy 

Act $1,000,000 $1,000,000 Not Indicated Expired 

12. GAO 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

13. OPM 

Not 

Indicated

Not 

Indicated

Not Indicated Not Indicated Not Indicated

14. DOS 

Economy 

Act $45,000 $45,000 Not Indicated Expired 

15. DOJ 

Economy 

Act $91,925 $91,925 Not Indicated Expired 

16. OPM 

Economy 

Act $56,371 $56,371 Not Indicated Expired 

17. OPM 

Economy 

Act $33,800 $33,800 Not Indicated Expired 

18. OPM 

Economy 

Act $5,437 $5,437 Not Indicated Expired 

19. MSPB 

Economy 

Act $5,000 $5,000 Not Indicated Expired 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 53 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 54 

Name of 

Servicing 

Agency 

Authority 

for IAA 

Total Cost Total 

Obligated 

Period of 

Performance

Status: Open, 

Expired, 

Closed 

20. OPM 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

Not Not Not Indicated Not Indicated Not Indicated

21. GPO Indicated Indicated

22. LOC 

Economy 

Act $37,029 $37,029 

Oct 1, 2007 – 

Sept 30, 2008 Expired 

23. GAO 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

Not Not Not Indicated Not Indicated Not Indicated

24. GSA Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

25. GAO Indicated Indicated

26. GSA 

Economy 

Act 

Not 

Indicated

Not Indicated Not Indicated Not Indicated

Not Not Not Indicated Not Indicated Not Indicated

27. FOH Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

28. DOI Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

29. MACASU Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

30. GSA Indicated Indicated

31. CFTC 

Economy 

Act $238,586 $238,586 Dec 31, 2008 Expired 

Not Not Not Indicated Not Indicated Not Indicated

32. GSA Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

33. GSA Indicated Indicated

34. WDC - Not Not Not Indicated Not Indicated Not Indicated

DPW Indicated Indicated

35. HUD 

Economy 

Act $64,478 $64,478 

Oct 1, 2005 - 

Sept 30, 2006 Expired 

Not Not Not Indicated Not Indicated Not Indicated

36. CAST Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

37. Treasury Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

38. QUINDI Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

39. SourceFire Indicated Indicated

40. Total Not Not Not Indicated Not Indicated Not Indicated

Recall Corp Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

41. DOJ Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

42. OPM Indicated Indicated

Not Not Not Indicated Not Indicated Not Indicated

43. DOC Indicated Indicated

Source: OIG Generated 
Appendix IX 

Expired IAAs With Outstanding Funding 

Table 5: Expired IAAs That Have Outstanding Funds 

Vendor 

Outstanding 

Amount 

IAA 

Expired

Closed and 

Deobligated 

Projected Date 

For 

Deobligating 

Funds and 

Closeout 

GSA OFFICE SUPP $735,228.21 Yes No First Qtr FY 2010 

GSA FEDSIM $5,277,003.42 Yes No First Qtr FY 2010 

UNICOR $49,096.65 Yes No First Qtr FY 2010 

GSAFTS1 $9,376.12 Yes No First Qtr FY 2010 

UNICOR $11,021.00 Yes No First Qtr FY 2010 

GSA, FEDERAL 

TECHNOLOGY SERV (FTS) $39,748.20 Yes No First Qtr FY 2010 

GSA Federal Technology 

Services National Capital 

Region $66,949.10 Yes No First Qtr FY 2010 

NARA $1,332.29 Yes No 

Before 30 Sept 

2009 

GSA PERSONAL 

PROPERTY CENTER $21,725.00 Yes No First Qtr FY 2010 

FEDLINK $3,173.97 Yes No 

Before 30 Sept 

2009 

GSA Federal Technology 

Services National Capital 

Region $11,580.00 Yes No First Qtr FY 2010 

DOI Payroll Service $2,880.00 Yes No First Qtr FY 2010 

FEDLINK FISCAL 

OPERATIONS $3,192.28 Yes No 

Before 30 Sept 

2009 

DEPARTMENT OF 

JUSTICE/ENRD $67,084.84 Yes No First Qtr FY 2010 

OFFICE OF PERSONNEL 

MANAGEMENT $3,099.20 Yes No First Qtr FY 2010 

U.S. DEPARTMENT OF 

TRANSPORTATION $80,001.00 Yes No First Qtr FY 2010 

U.S. GENERAL 

ACCOUNTING OFFICE $190,487.00 Yes No 

Before 30 Sept 

2009 

THE OFFICE OF 

COMPTROLLER OF THE 

CURRENCY $33,668.99 Yes No First Qtr FY 2010 

FEDSOURCE $187,832.93 Yes No First Qtr FY 2010 

GSA VERIZON $58,303.29 Yes No First Qtr FY 2010 

UNICOR $587.44 Yes No First Qtr FY 2010 

OPM $40,000.00 Yes No First Qtr FY 2010 

Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 55 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 56 

DOT $52,459.76 Yes No First Qtr FY 2010 

Total $6,945,830.69 

Source: OIG Generated 
Management and Oversight of IAAs at the SEC March 26, 2010 

Report No. 460 

Page 57 

Appendix X 

Schedule of Cost Savings 

Table 6. Schedule of Cost Savings

Number of Expired IAAs Amount to 

De-obligate 

Cost 

Savings 

23 (See Appendix IX) $6,945,831 $6,945,831

Total $6,945,831 $6,945,831 

Source: OIG Generated 
Audit Request and Ideas

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request an audit in the future or have an audit idea, please contact us at: 

U.S. Securities and Exchange Commission 

Office of Inspector General 

Attn: Assistant Inspector General, Audits (Audit Request/Idea) 

100 F Street, N.E. 

Washington D.C. 20549-2736 

Tel. #: 202-551-6061 

Fax #: 202-772-9265 

Email: oig@sec.gov 

Hotline 

To report fraud, waste, abuse, and mismanagement at SEC, 

contact the Office of Inspector General at: 

Phone: 877.442.0854 

Web-Based Hotline Complaint Form: 

www.reportlineweb.com/sec_oig