U.S. OFFICE OF PERSONNEL MANAGEMENT 

OFFICE OF THE INSPECTOR GENERAL 

OFFICE OF AUDITS 

Final Audit Report 

Subject: 

AUDIT OF THE U.S. OFFICE OF PERSONNEL 

MANAGEMENT'S SECURITY GUARD CONTRACT 

Report No. 4A-CA-OO-09-043 ( 

\ 

Date: January 21, 2010 

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--CAUTION-­

This audit report has be~n distributed to Federal officials who are 'responsible for the administration of the audited program. 

This audit report may contain proprietary data which is protected by Federal law (18 U.S.c. 1905). Therefore, wbile this 

audit report is available umler the Freedom of III formation Act and made available to the publk on the OIG web page, caution 

needs to be extrci$Cd before releasing the report 10 Ihe general public as it may contain proprietary information tbal was 

redacted from the publ,icly distributed copy. 

" .... , 
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 


Washington, DC 20415 


Office of the 

Inspector General 

AUDIT REPORT 

AUDIT OF THE U.S. OFFICE OF PERSONNEL 


MANAGEMENT'S SECURITY GUARD CONTRACT 


Report No. 4A-CA-OO-09-043 Date: January 21, 2010 

Michael 

~~ R. Esser 

Assistant Inspector General 

for Audits 

www.opm.gov www.usajobs.gov 
UNITED STATES OFFICE OF PERSONNEL MANAGEMENT 


Washington, DC 20415 


Office of the 

Inspector General 

EXECUTIVE SUMMARY 

AUDIT OF THE U.S. OFFICE OF PERSONNEL 


MANAGEMENT'S SECURITY GUARD CONTRACT 


Report No. 4A-CA-OO-09-043 Date: January 21, 2010 

The Office of the Inspector General has completed a performance audit of the U.S. Office of 

. PersOimel Management's (OPM's) Security Guard Contract. Our main objective was to 

determine whether the Center for Security and Emergency Actions (CSEA) is providing effective 

oversight ofOPM's Security Guard Contract. In order to make this determination, our audit 

included the following specific objectives: (1) to detemline if the OPM security guards working 

under the cunent contract meet the qualifications and training requirements; and (2) to detelmine 

ifCSEA is effectively monitoring the perfonnance ofthe contracted guard force. 

Our audit was conducted fiom July 20,2009 through September 30, 2009 at OPM's headqumters 

in Washington, D.C. OUf audit identified three areas requiring improvement. 

A. Security Guard Qualifications 

1. Lack of Training and Certification Policies Procedural 

The Center for Security and Emergency Actions did not have 

documented policies aIld procedures in place to ensure that 

all security guards working on the OPM contract had cunent 

training and certifications. 

www.opm.goy www.usajobs.goY 
B. Security Guard Contract Oversight 

1. Inadequate Quality Assurance Surveillance Plan (QASP) 

Performance Measurements 

Procedural 

The current QASP is ineffective in measuring the true 

performance ofthe security guard contract. 

2. Post Inspection Policy Not Followed Procedural 

CSEA has not effectively followed its Post Inspection policy 

to ensure that the security guards are properly securing the 

Theodore Roosevelt Building. 

11 
TABLE OF CONTENTS 


EXECUTIVE SUMMARY ...................................................... 


I. INTRODUCTION AND BACKGROUND......... ......... ...... ..... ...... 1 


II. OBJECTIVES, SCOPE, AND METHODOLOGy...................... 3 


III. AUDIT FINDINGS AND RECOMMENDATIONS.................... 5 


A. Security Guard Qualifications 

1. Lack of Training and Certification Policies...... ............ ...... 5 


B. Security Guard Contract Oversight 

1. Inadequate Quality Assurance Surveillance Plan 


Performance Measurements .......................................... 7 


2. Post Inspection Policy Not Followed........ ............... ..... ..... 8 


IV. MAJOR CONTRlBUTORS TO THIS REPORT.................... ..... 10 


APPENDIX 	 (Center for Security and Emergency Actions Response, dated 

November 19, 2009, to our draft report) 
I. INTRODUCTION AND BACKGROUND 


Introduction 

This final audit report details the findings, conclusions, and recommendations resulting from our 

performance audit ofthe U.S. Office of Personnel Management's (OPM) Security Guard 

Contract. The audit was performed by OPM's Office ofthe Inspector General (OIG), as 

authorized by the Inspector General Act of 1978, as amended. 

Background 

41 CFR 102-81.10 states that "Federal agencies on Federal property under the charge and control 

ofthe Administrator and having a security delegation of authority from the Secretary of 

Homeland Security must provide for the security and protection ofthe real estate they occupy, 

including the protection of persons within the property." OPM's Management Services 

Division's (MSD) Center for Security and Emergency Actions (CSEA) administers and provides 

oversight ofOPM's Security Guard Contract. The Contracting Officer Technical Representative 

(COTR) is responsible for the administration ofthe contract and for assuring compliance by the 

contractor with the requirements of the contract. CSEA's primary mission is to ensure a safe and 

secure work environment so that OPM business can proceed in an uninterrupted fashion at the 

Theodore Roosevelt Building (TRB). 

OPM provides for the protection ofthe TRB via contract security guards. OPM awarded a fixed 

price contract (Contract no. P00407000425) through the General Services Administration 

schedule in August 2007 to American Security Programs (ASP). The base year of the contract 

was from September 1,2007 to August 31, 2008 with four one-year renewal options through 

December 28,2012. American Security Programs is currently in the second of the four one-year 

renewal options. 

The contract states that the contractor shall provide armed guard services and appropriate 

supervision to satisfactorily perform the access control and security services at the TRB in 

accordance with established post orders. In addition, the contract maintains that the contractor 

shall use properly trained employees at all times to perform the services, as prescribed in the 

contract. The contractor will certify completion of all training requirements. No employee will 

be assigned to perfonn under the contract without written notice to the contractor from the 

Contracting Officer's Representative (COR), approving the firearms licensing and qualifications 

ofthe individual employees. 

The Federal Protective Service (FPS) Security Guard Information Manual provides information 

on the primary responsibilities of security guards to control access to Federal property and to 

assist in ensuring the safety of Federal property, employees, and visitors. Access controls 

include checking visitors' and employees' identification; operating security equipment, such as 

X-ray machines and Magnetometers to screen for prohibited materials; and reporting crimes and 

incidents to security personnel. 

1 

OPM's Post Instructions and Orders provide the duties required of the security guards at each 

guard post. The post instructions contain all current policies, orders/instructions, emergency 

procedures, and any other information deemed pertinent to the TRB. The security guards are to 

comply with all post instructions detailing responsibilities and duties to be performed at each 

post, including general security guard code of conduct policies. 

Contractor performance is evaluated via the Quality Assurance Surveillance Plan (QASP). The 

QASP contains performance metrics that the security guards are evaluated against in terms of 

compliance with the tenns of the contract and related policies and procedures and contractor 

responsibilities. These include staffing, physical security, updating and maintaining 

certifications, reconciliation of 139s (Record ofTime ofArrival and Departure Contract Guard 

Duty Register), management and customer service/public relations, and professionalism. The 

categories of performance have an acceptable quality level (AQL) with payment 

incentives/reductions based on the actual level of perfonnance attained as compared to the AQL. 

The recommendations from our previous audit of OPM's Security Guard Contract (Report No. 

4A-CA-OO-03-034), dated July 23, 2003, have been satisfactorily resolved. 

2 

II. OBJECTIVES, SCOPE, AND METHODOLOGY 


Objectives 

Our audit objective was to detemline whether OPM has effective oversight ofOPM's 

Security Guard Contract. Specifically, our objectives were to: 

• 	 Determine if the OPM security guards working under the current contract 

meet the qualification and training requirements. 

• 	 Determine if CSEA is monitoring performance of the security guard force 

according to the QASP. 

The recommendations included in this final report address these objectives. 

Scope and Methodology 

We conducted this performance audit in accordance with generally accepted government 

auditing standards as established by the Comptroller General of the United States. Those 

standards required 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. 

The scope of our audit covered OPM's current contract with ASP. 

We performed our audit from July 20 to September 30, 2009 at OPM headquarters in 

Washington, D.C. 

To accomplish the audit objectives noted above, we: 

• 	 Sampled, reviewed, and tested guard qualifications and certifications for 

compliance with requirements; 

• 	 Sampled, reviewed, and tested CSEA's implementation of the QASP; 

• 	 Sampled, reviewed, and tested CSEA's post inspection policies and 

procedures; and, 

• 	 Interviewed key representatives from CSEA responsible for managing the 

security guard contract. 

In planning our work we gained an understanding of the internal controls over CSEA's 

oversight ofthe security guard contract. We also considered the internal control structure 

to the extent necessary to develop our audit procedures. These procedures mainly were 

substantive in nature. We did gain an understanding of management procedures and 

controls to the extent necessary to develop our audit objectives. The purpose of our audit 

is not to provide an opinion on internal controls, but merely to evaluate controls over the 

processes that were included in the scope ofour audit. Our audit included tests of 

3 

contract guard training and certification files~ verification and validation of QASP results 

and post inspections; and other auditing procedures as we considered necessary under the 

circumstances. The resuJts of our tests indicate that CSEA has adequate controls in place 

for providing effective oversight ofOPM's security guard contract (P00407000425), 

except for the areas set forth in the details of this audit report. 

In conducting our audit, we judgmentally selected 24 of 67 security guards assigned to 

work on OPM ContractP00407000425. We reviewed training folders in order to 

determine if each security guard received the following training: 

• Basic training as described in the FPS Security Guard Information Manual; 

• Supervisory training (for supervisory level guards); 

• 40-hour firearms training course and yearly recertification; 

• Cardiopulmonary resuscitation (CPR) training with yearly recertification; 

• First Aid course with recertification every three years; and 

• Baton training course with recertification every two years. 

In addition, we randomly selected four months (February, April, May and June) ofQASP 

results and post inspections from the current contract period to test CSEA's oversight of 

the security guard contract. 

The results from the various samples were not projected to the population. 

4 

III. AUDIT FINDINGS AND RECOMMENDATIONS 


Our audit disclosed that, with respect to the items tested, OPM has adequate controls in place for providing 

effective oversight of its security guard contract, except for the areas set forth in the details of this audit 

report. The areas requiring improvements are described below. 

A. Security Guard Qualifications 

1. Lack of Training and Certification Policies 

CSEA did not have documented policies and procedures in place to ensure that all security 

guards working on the OPM Contract had current training and certifications. During our 

audit, we found that 3 of the 24 security guards' training folders sampled did not contain 

evidence oftraining or certification for one or more of the required training classes and 

certifications. 

FPS stipulates the following training requirements and certifications that all contract guards 

in Federal buildings must complete: 

• Basic training as described in the FPS Security Guard Information Manual; 

• Supervisory training (for supervisory level guards); 

• 40-hour firearms training course and yearly recertification; 

• Cardiopulmonary resuscitation training with yearly recertification; 

• First Aid course with recertification every three years; and 

• Baton training course with recertification every two years. 

Contract P00407000425 states that the contractor shall use properly trained employees at all 

times to perform the services as prescribed in the Contract and will certify completion of all 

training requirements. No employee will be assigned to perform under the Contract without 

written notice to the contractor from the COR or COTR, approving the firearms licensing and 

qualifications of the individual employees. In addition, no contractor employee shall work 

under the Contract without a valid Federal Protective Service (FPS) certification card. 

CSEA does not proactively evaluate the training and certifications of the security guards 

working on the OPM Contract. While all missing documentation was provided during the 

course of our audit, the lack of documented policies and procedures for obtaining and 

maintaining evidence of training increases the risk that the contracted security guards 

responsible for securing the Theodore Roosevelt Building may be working on the OPM 

Contract without proper training. 

Recommendation 1 

We recommend that CSEA perform a comprehensive review of all security guards' training 

and certification documentation to ensure that training and certifications are current and 

available. 

5 
Recommendation 2 

We recommend that CSEA develop policies and procedures for reviewing training and 

certification documentation for contracted security guards. 

CSEA~s Response: 

"While there is no regulatory, statutory or contractual requirement for the tracking or 

maintenance ofdocumentation of each individual training!certification element which 

comprises the FPS A-I certification, CSEA has traditionally tracked this infonnation as an 

added assurance that guards working on the TRB contract are appropriately trained and 

vetted. While the training records CSEA maintains were incomplete for 3 of the 24 

individuals sampled, it is important to note that all 3 individuals maintained valid FPS A-I 

certifications. As such, at no time were any of the guards assigned to OPM posts without 

proper and valid training certifications." 

"As recommended, CSEA has conducted a thorough review of all the training and 

certifications for each guard. Documentation for each individual training/certification 

element is current. The OIG has been provided with evidence to show that the 3 individuals 

missing training records were in fact current at the time ofthe OIG review. We will continue 

to maintain up-to-date training and certifications for all guards. As noted in the OIG draft 

report, we have prepared a draft standard operating procedure (SOP) for our COR in an effort 

to improve our oversight ofthe guard program. We look forward to working with the OIG 

closely to fine tune the SOP prior to issuance." 

OIG Comment for Recommendation 1: 

CSEA provided documentation to support the review of all security guards' training files and 

the creation of a binder to maintain and support training and certification of all security 

- guards working on the contract. We have reviewed the documentation and consider this 

recommendation closed. 

OIG Comment for Recommendation 2: 

CSEA provided documented standard operating procedures for reviewing security guard 

training and certification documentation. The procedures detail the training and certification 

documentation that must be obtained and documented for each security guard workingon the 

contract. We have reviewed the documentation and consider this recommendation closed. 

6 

B. Security Guard Contract Oversight 

1. Inadequate Qualitv Assurance Surveillance Plan (QASP) Performance Measurements 

The current QASP is ineffective in measuring the true performance of the security guard 

contract. Specifically, the performance measures used in evaluating security guard 

performance and completing the QASP are primarily SUbjective. During our audit, we were 

unable to validate how actual perfonnance levels were obtained for the months sampled. The 

COTR provided explanations of how the QASP actual perfonnance levels are calculated, 

which include post inspections, incident reporting, customer complaints (non-verbal), and 

reviewing Form 139s, which record the security guards' time of arrival and departure. 

However, the COTR also utilizes undocumented measures, such as individual knowledge of 

the contractor's operations, daily observation, and verbal customer complaints to measure the 

contractor's performance. 

Contract P00407000425 states that the QASP is OPM's codification of its method of 

implementing FAR 37.601, which requires that performance-based contracts describe 

requirements in terms of results rather than methods of work perfonnance; use measurable 

performance standards (i.e., quality, timeliness, quantity, etc,) and quality assurance 

surveillance plans; and specify the procedures used in reducing fees or the price of a fixedprice contract when services are not performed or do not meet contract requirements. 

The Contract also states that the QASP should contain a performance standard element in 

which important items are measurable; performance is auditable and capable of validation 

(less subjective, quantifiable measures are preferred); and have a level of detail that 

corresponds to the intent ofthe stated measure and expectation. 

Based on the current QASP, the COTR does not have an effective tool to measure ASP's 

contract performance. 

Recommendation 3 

We recommend that OPM's CSEA work with the Contracting Officer to revise its QASP to 

ensure that it includes perfonnance measures that are auditable and capable of validation. 

CSEA's Response: 

"Toe QASP was incorporated in the Guard Services Contract, OPMP0040700042[5], and 

modification 002, as required by Federal Acquisition Regulation (FAR) 37.601. The QASP 

identifies critical categories, performance standards of those categories, the acceptable 

quality level, and the method in which those categories would be monitored. Furthermore, 

the QASP established performance incentives and addressed disincentives in compliance 

with the FAR. We believe the measures are objective, though we welcome all infOlmation 

on how to improve the performance measures." 

7 
OIG Comment: 

CSEA provided its revised draft QASP for review. The revised QASP contains measurable 

performance standards, and the QASP procedures define exactly how to measure each 

standard. This recommendation will remain open until the revised QASP is approved by 

Contracting and CSEA has implemented the QASP and provides actual performance results 

for verification and validation. 

2. 	 Post Inspection Policy Not Followed 

CSEA has not effectively followed its Post Inspection policy to ensure that the security 

guards are properly securing the TRB. Based on our review ofdocumented post inspections 

for the four months sampled, CSEA was not able to substantiate that post inspections were 

conducted in accordance with CSEA policy (two times per week). CSEA only conducted 

one post inspection for each of the months tested. From the documentation provided we 

established that: 

• 	 CSEA did not perform the required number afpast inspections for the months 

sampled, and 

• 	 There is no weighting of post inspections as it applies to the QASP. 

During our physical inspections, the following deficiencies were noted: 

• 	 One guard was reading while on duty; 

• 	 Some guards on duty stated they had not received random radio checks once every 

hour; and 

• 	 Post Orders were not in the proper locations (at the post for which the orders were 

established) . 

.-In addition, during our physical post inspection review, we observed an ASP training 

exercise where the contractor's test subject successfully gained access to the TRB with a 

"'fake" gun concealed in the bottom of a laptop case. Following the exercise, all TRB 

security guards were instructed in the proper handling of laptops. Furthermore, signage has 

been posted at TRB guard posts requesting the removal of laptops from bags prior to 

scanning. 

CSEA's Contract Guard and Post Inspection policy states that the COTR or designated 

representative is responsible for conducting inspections of contract security guards and posts 

at least twice a week during duty hours and at least once every other week during non-duty 

hours.. 

If posts are not properly maintained, TRB security may be at risk. 

8 
Recommendation 4 

We recommend that OPM's CSEA follow its Post Inspection policy and perfonn inspections 

at least twice a week during duty hours and at least once every other week during non-duty 

hours. . 

CSEA's Response: 

"CSEA is currently conducting daily post inspections. Since CSEA has a 24 hour, 7 days per 

week presence within the TRB, we have the ability to provide continuous oversight ofthe 

guard contract to include weekends, holidays and non-core duty hours. We also confer daily 

with the guard Project Manager to ensure proper compliance with our requirements. CSEA 

has developed a draft updated CSEA Post Inspection Report checklist, which has been 

provided to the OIG." 

OIG Comment: 

We evaluated the COTR's SOPs for the post inspections, which include specific 

requirements for the post inspection process, such as defining what a post and post 

inspections are and the types of post inspections that should be completed. CSEA also 

provided a revised version ofthe post inspection checklist. CSEA has defined in their SOP's 

what the post inspection process entails and has redesigned the checklist so that each guard 

on duty can be evaluated at each post. We obtained the Post lnspection checklists for the 

month of October and have validated that the inspections are being performed according to 

CSEA's new "policy" of conducting daily post inspections. We consider this 

recommendation closed. . 

9 

IV. MAJOR CONTRIBUTORS TO THIS REPORT 

Internal Audits Group 

. Team Leader 

Jr., Chief 

10 

APPENDIX 

UNITED STATES OFFICE OF PERSONNEL MANAGEMENT .,' .•... -.. 2009 NOV 20 f+t1~tn4~, DC 20415 

Management Services 

Division November 19, 2009 

MEMORANDUM FOR 

FROM: 

Chief, Internal Audits Group 

Office ofInspector Geneml 

DEAN 

Deputy 

S. 

Associate 

HUNTER 

Director ~~ -

Center for Security and rgency Actions 

SUBJECT: 	 Response to Draft Report on the Audit ofthe U.S. Office of Personnel 

Management's (OPM) Security Guard Contract 

Please accept my sincere thanks and appreciation for the Office ofInspector General's (OIG) -Faudit ofthe Theodore Roosevelt Building (TRB) security guard contract (Report No. 4A-CA-OO- .. 

00-043). The security and safety of OPM employees, contractors and visitors at the TRB require 

our strong commitment to provide a safe and secure work environment. Your audit provides an o. 

opportunity to examine and improve our guard operations, as appropriate. Our response to the 

OIG draft audit report findings and recommendations is provided below: 

OIG Finding #1: Ineffective Training and Certification Policies: The Center for Security and 

Emergency Actions does not have policies and procedures in place to ensure that all secl.lrity 

guards working on the OPM contract have current training and certifications. 

OIG Recommendation #1: We recommend that CSEA perform'a comprehensive 

review of all security guards' training and certification documentation to ensure that 

training and certifications are current and available. 

OIG Recommendation #2: We recommend that CSEA develop policy and procedures 

for reviewing training and certification documentation for contracted security guards. 

CSEA Response: In accordance with the contract, a guard must obtain and maintain 

Federal Protective Service (FPS) A-I certification. The guard demonstrates adherence to 

the A-I certification by possession ofICE Form 78-3527, DHS Contract Guard 

Certification Card, or Section J, Exhibit 4A, Contractor's Certification ofBasic Tmining, 

which are both issued by FPS, a component ofthe Department of Homeland Security 

(DHS). Possession ofthe FPS Contract Guard Certification Cardandlor Section J, 

Exhibit 4A, Contractor's Certification of Basic Training, satisfies by contract that the 

guard meets the training and certification requirements for performance as a guard at 

OPM. 

www.opm.gov Our mission is to ensure the Federal Government has an effective civilian workforce www.usaJ.obs.gov 
While there is no regulatory, statutory or contractual requirement for the tracking or 

maintenance ofdocumentation of each individual training/certification element which 

comprises the FPS A-1 certification, CSEA has traditionally tracked this information as 

an added assurance that guards working on the TRB contract are appropriately trained 

and vetted. While the training records CSEA maintains were incomplete for 3 ofthe 24 

individuals sampled, it is important to note that all 3 individuals maintained valid FPS AI certifications. As such, at no time were any ofthe guards assigned to OPM posts 

without proper and valid training and certifications. 

Before assignment of a guard at OPM, the guard company presents appropriate training 

and certification documentation to our COR. Upon favorable review ofthe training and 

certification by the COR the guard is permitted to perfonn as a guard at OPM. For 

example, we have recently completed the background investigation on 3 new guards, but 

they are not being permitted onsite at OPM to perfonn as a guard lllltil we receive 

validation ofthe guard training and certification requirements from the guard company. 

Additionally, the COR has a very close and daily relationship with the guard company 

Project Manager who is onsite at OPM, and our COR aggressively monitors any change 

in our guard's training, certification, or performance. 

As recommended, CSEA has conducted a thorough review of al] the training and 

certifications of each guard. Documentation for each individual training/certification 

element is current. The OIG has been provided with evidence to show that the 3 

individuals missing training records were in fact current at the time ofthe OIG review. 

We win continue to maintain up-to-date training and certifications for all guards. As 

noted in the OIG draft report, we have prepared a draft standard operating procedure 

(SOP) for our COR in an effort to improve our oversight ofthe guard program. We look 

forward to working with the OIG closely to fme tune the SOP prior to issuance. 

In addition to the actions noted above, CSEA has undertaken additional efforts above and 

beyond the current contract to ensure that the TRB guard force is capable of ensuring the 

safety and security ofOPM employees and visitors on a daily basis. CSEA has secured 

advanced x-ray and magnetometer training for all guards from the Federal Protective 

Service. Further, CSEA recently procured and provided to the guards advanced xray/video training for enhanced detection of explosives, which is accessible at any time 

during our x-ray operations. Our COR has attended guard firearm training qualifications 

and has provided enhanced training to the guards on response operations at OPM in event 

of an H1NI flu epidemic. In addition, we have partnered with the guard company in the 

development ofa contract guard proficiency exam, as well as a covert testing ofguard xray screening capabilities. These measures are not required by contract, but demonstrate 

CSEA's commitment to ensure high quality security guard services at the TRB. 

OIG Finding # 2: Inadequate Quality Assurance Surveillance Plan (QASP) Performance 

Measurements: The current QASP is ineffective in measuring the true perfonnance ofthe 

security guard contract. 
OIG Recommendation #3: We recommend that OPM's CSEA revise its QASP to 

ensure that it includes quantifiable measures for evaluating guard performance. 

CSEA Response: TJIe QASP was incorporated in the Guard Services Contract, 

OPMP0040700042, and modification 002, as required by Federal Acquisition Regulation 

(FAR) 37.60L The QASP identifies critical categories, performance standards ofthose 

categories, the acceptable quality level, and the method in which those categories would 

be monitored. Furthermore, the QASP established performance incentives and addressed 

disincentives in compliance with the FAR. We believe the measures are objective, 

though we welcome all information on how to ~prove the performance measures. We 

are actively working with the OIG to address these issues. 

OIG Finding #3: Ineffective Post Inspection Policy: CSEA's post inspection policy is not 

effective in ensuring that OPM is properly secured. 

Recommendation #4 deleted by OPM/OIG/IAG. Recommendation #5 (below) is now 


Recommendation #4. 


OIG Recommendation #5: We recommend that OPM's CSEA follow its post 

inspection policy and perform inspections at least twice a week during duty hours and at 

least once every other week during non-duty hours: 

CSEA Response: CSEA is currently conducting daily post inspections. Since CSEA has 

a 24 hour, 7days per week presence within the TRB, we have the ability to provide 

continuous oversight of the guard contract to include weekends, holidays and non-core 

duty hours. We also confer daily with the guard Project Manager to ensure proper 

compliance with our requirements. CSEA has developed a draft updated CSEA Post 

Inspection Report checklist, which has been provided to the OIG. 

The post inspection process and depth ofreview/inspection recommended by the OIG 

does pose a concern to CSEA in regards to compliance with the existing contract. We 

will consult with the OPM Contracting Officer to ensure that revised inspection 

procedures are com~istent with the existing contract and do not constitute a personal 

services contract, which we understand is not permitted. Our staff comment about their 

"inspection" of the guards is actually surveillance of guard performance as it relates to 

the QASP. The QASP is the contractual vehicle by which we survey the guard 

company compliance with our security requirements. 

Again, we thank you for your efforts to improve the contract guard services at the TRB and we 

appreciate the opportunity to comment on the draft audit report.. If additional information is 

required, please have a member of your staff contact Chief, Security Services 

Group, at (202) 606_