Department of Veterans Affairs 

Office of Inspector General 

 Review of Interagency Agreement 

between the Department of 

 Veterans Affairs 

and 

 Department of Navy, Space and

Naval Warfare Systems Center
 

(SPAWAR) 

Report No. 09-01213-142 June 4, 2009
 

VA Office of Inspector General 

Washington, DC 20420 
 

 

 

To Report Suspected Wrongdoing in VA Programs and Operations 

Telephone: 1-800-488-8244 between 8:30AM and 4PM Eastern Time,

 Monday through Friday, excluding Federal holidays

 E-Mail: vaoighotline@va.gov 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Contents 

Executive Summary .................................................................................................i
 

Introduction 

Purpose ................................................................................................................1 

Background..........................................................................................................1 

Scope and Methodology......................................................................................3 

Results 

Issue 1: Compliance with Interagency Agreement Terms and Conditions ...........5 

Issue 2: Poor Administration of IAA ..................................................................17 

Issue 3: Lack of Cost Controls ............................................................................20 

Issue 4: Other Matters to be Reported ................................................................23 

Conclusions and Suggestions ...............................................................................27 

Appendices 

A. Projects Identified Under Amendments 1 through 22.......................................30 

B. OIG Contact and Staff Acknowledgements ......................................................32 

C. Report Distribution............................................................................................33 

VA Office of Inspector General 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Executive Summary 

Introduction 

At the request of the Secretary of Veterans Affairs and Ranking Minority Member of the 

House Committee Veterans’ Affairs, we conducted a review of the Interagency 

Agreement (IAA) between the Department of Veterans Affairs (VA), Office of 

Information and Technology (OI&T), Office of Enterprise Development (OED), and the 

Space and Naval Warfare Systems Center (SPAWARSYSCEN), hereinafter referred to 

as SPAWAR. 

The IAA was entered into in November 2007, under the authority of the Economy Act, 

31 U.S.C. § 1535, to provide “government employee and contractor technical support for 

analysis, planning, program review and engineering services for Information 

Management/Information Technology (IM/IT) initiatives.” 

Although the IAA does not include specific requirements or deliverables, VA obligated 

and transferred $2.5 million to SPAWAR when the agreement was executed. According 

to the IAA, this was the total estimated funding needed for Fiscal Year 2008. Since the 

agreement was executed in November 2007 funding has increased from $2.5 million to 

$66 million. Twenty-two (22) amendments supporting 30 projects have been issued 

against the IAA. Sixteen (16) of the 22 amendments, totaling $25,695,066, were issued 

in September 2008. Currently, there are 26 projects in the pipeline to be issued which 

will add an additional $73 million to the IAA. VA obligates the funds to the IAA at the 

time each amendment is executed. The amount obligated represents the amount 

identified in the Independent Government Cost Estimate (IGCE) contained in the 

accompanying Statements of Work (SOW). 

Results 

We found that the IAA was entered into without an adequate analysis to determine that 

the “use of an interagency acquisition is in the best interest of the Government” as 

required by FAR 17.503. We also found that neither VA nor SPAWAR has complied 

with the terms and conditions of the IAA. We found that the SOW and the IGCEs that 

VA was supposed to develop were actually developed by SPAWAR and SPAWAR 

contractors. We also found that the SOW were often broad and general in nature and 

lacked specific deliverables. We also identified amendments that were outside the scope 

of the IAA as well as unauthorized work being performed on projects that were not 

within the scope of the amendments. 

VA Office of Inspector General i 
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and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Problems with the implementation of the IAA are due to poor administration by both 

OED and SPAWAR. OED was not performing adequate oversight to ensure that funds 

were spent appropriately. For example, VA was unaware that SPAWAR contracted out 

approximately 87 percent of the work requested through the IAA. OED could not tell us 

who was performing the work under the IAA, how many people were providing services, 

or where they were located. Although the amendments to the IAA indicate that SPAWAR 

anticipated employing the services of 295 FTE, the resource roster prepared by 

SPAWAR shows that only 217 FTE are providing services. Of the 217 FTE, 22 are 

SPAWAR employees and the remaining 195 FTE are working for contractors and 

subcontractors. The IAA does not address the issue of management fees paid to 

SPAWAR for providing services under the IAA and OED was unaware of the fees being 

charged by SPAWAR. Also, SPAWAR was unable to provide justification or authority 

to charge a 10 percent management fee. 

We also attribute problems with the administration of the IAA to insufficient technical 

and legal reviews conducted by the Office of Acquisition, Logistics & Construction 

(OAL&C) and the Office of General Counsel (OGC), respectively. These reviews should 

have identified that amendments were outside the scope of the IAA and that the SOW did 

not include specific tasks or deliverables or were inconsistent with the corresponding 

amendment. We concluded that OED has relinquished its oversight role of financial 

performance and work performed under the IAA to SPAWAR. 

In addition to problems with VA’s failure to properly administer the IAA, we also 

identified deficiencies on the part of SPAWAR. We determined that SPAWAR did not 

ensure that VA paid fair and reasonable prices for the services provided. SOW for task 

orders that SPAWAR issued to contractors did not identify specific tasks or deliverables. 

We also found that SPAWAR contractors were subcontracting the work to other 

SPAWAR contractors at the direction of SPAWAR. This practice unnecessarily 

increases the cost because VA must pay an additional layer of management fees and 

overhead. In reviewing contracts that SPAWAR issued to vendors performing services 

under the IAA, we found that SPAWAR executed an option year more than 6 months 

prior to the expiration of the contract’s base year. Because the option year prices were 

higher, VA unnecessarily incurred higher costs for the work performed by this contractor. 

Neither the IAA nor any of the task orders issued by SPAWAR to its contractors that we 

reviewed contain the VA required system security and privacy requirement clauses for: 

Information Security, Cyber Security, and Privacy Policy. Absence of these requirements 

places VA systems and information at risk by SPAWAR and its contractors. 

In addition, an Amendment that required SPAWAR to purchase IT equipment and 

software contained a provision requiring SPAWAR to comply with OI&T established 

policy requiring the use of NASA SEWP IV contracts for all IT acquisitions and that 

VA Office of Inspector General ii 
 

 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

waivers must be requested and approved through the IT Tracker approval process. 

Amendment 20 to the IAA struck the requirement that SPAWAR use the SEWP contract. 

However, no one in VA was able to provide any documentation that a waiver was 

processed. 

Suggestions 

We suggest that VA take steps to re-evaluate the IAA and determine whether it is in the 

best interests of VA to continue obtaining services through this type of agreement. If it is 

determined to be in VA’s interest to continue with an IAA to obtain services to support 

OED, we suggest issuing a new IAA that complies with the requirements of Information 

Letter (IL) 001AL-09-04, dated March 23, 2009. The IL establishes VA policy for 

Managing Interagency Acquisitions, and incorporates requirements contained in guidance 

issued by the Office of Federal Procurement Policy in a Memorandum dated 

June 6, 2008, titled “Improving the Management and Use of Interagency Acquisitions.” 

We also suggest that: 

•	 The restructured IAA should emphasize training of VA personnel to better 

manage OED programs and operations and to learn to develop SOW and monitor 

contractor performance. It should also require VA personnel to actively 

participate in the development, award, and administration of contracts to third 

parties to provide services under the IAA. 

•	 OAL&C contracting officers and OGC need to implement processes to improve 

their technical and legal reviews of the IAA, amendments or modifications 

thereto, and the SOW. 

•	 VA should be required to prepare the SOW with specific tasks, deliverables, 

defined delivery dates, and performance measures. 

•	 OED should be required to develop IGCEs as a method of determining the 

reasonableness of proposed cost estimates. The IGCEs should identify labor 

hours and labor categories by task. OED in conjunction with OAL&C should 

determine, on a task basis, whether it is in VA’s best interest to enter into firm 

fixed-price contracts with third parties versus cost-reimbursement or time and 

materials contracts. 

•	 OED should require SPAWAR, or any other Government entity that is party to an 

IAA, to provide financial reports that identify the hours worked by labor category 

and task, and indicate whether the employee is a Government or contract 

employee. 

•	 All amendments and SOW should identify VA program managers who are 

actually performing those duties and responsibilities, and are accountable for the 

outcomes. 

VA Office of Inspector General iii 
Review of Interagency Agreement Between the Department of Veterans Affairs 

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•	 VA should establish policies and procedures for program managers to certify that 

they have reviewed monthly SPAWAR financial documents and progress reports 

and have concurred with them. 

•	 VA should establish a single point of contact within OED to warehouse all 

documents and deliverables required under the IAA and amendments. In 

addition, all VA program managers and project officers should be required to 

maintain all documents provided by SPAWAR under the IAA and Amendments. 

•	 Costs associated with Program Management Support provided by SPAWAR 

should be proposed and reported under a separate amendment. 

•	 VA should cease issuing amendments with multiple unrelated projects and 

multiple amendments for the same project/work. Previously issued amendments 

can be modified to add additional tasks, and such tasks can be tracked and 

reported by SPAWAR. 

(original signed by:) 

MICHAEL GRIVNOVICS
 

Director, Division B 

Office of Contract Review
 

VA Office of Inspector General iv 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Introduction 

Purpose 

At the request of the Secretary of Veterans Affairs and Ranking Minority Member of the 

House Committee Veterans’ Affairs, we conducted a review of the Interagency 

Agreement (IAA) between the Department of Veterans Affairs (VA), Office of 

Information and Technology (OI&T), Office of Enterprise Development (OED), and the 

Space and Naval Warfare Systems Center (SPAWARSYSCEN), hereinafter referred to 

as SPAWAR. Our review objectives included an assessment of: 

• The IAA’s administrative requirements 

• Compliance with the terms and conditions of the IAA 

• VA’s management and oversight of the IAA 

• SPAWAR’s management of the IAA 

• Services or products delivered 

• Other matters affecting the IAA 

Background 

On November 7, 2007, OI&T, OED entered into a one year IAA with SPAWAR under 

authority of the Economy Act, to provide “government employee and contractor technical 

support for analysis, planning, program review, and engineering services for Information 

Management/Information Technology (IM/IT) initiatives.” 

OED is a major organization within OI&T that serves as the chief advisor to the Assistant 

Secretary for Information and Technology for all enterprise application development 

activities. Development consists of planning, developing (or acquiring), and testing 

applications that meet VA’s business requirements. It provides day-to-day direction over 

all solutions developed by OI&T for VA business units. 

SPAWAR is a component of the United States Navy located in Charleston, South 

Carolina. SPAWAR provides knowledge superiority to joint warfighters and 

peacekeepers through the development, acquisition, and life cycle support of effectively 

integrated Command, Control, Communications, Computers, Intelligence, Surveillance 

and Reconnaissance (C4ISR) systems, Information Technology (IT), and Space 

capabilities. The IAA is being performed by SPAWAR Charleston’s Information 

Assurance and Engineering Division, Health Systems Organization (HSO). Within the 

HSO, the following structure has been established to provide services to VA under the 

IAA: 

VA Office of Inspector General 1 
 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

•	 Program Manager (PM) has been designated to have direct authority over all VA 

related programs/projects 

•	 Deputy PM of Execution – responsible for the day to day management and 

oversight of all VA operations and Program Support Office 

•	 Program Support Office – service level support in project management, project 

planning, cost management, HR support, administration, and logistics 

•	 OPERATIONS, IPRM and OED –Integrated Project Team Leads/Operations 

Managers responsible for cost, schedule, performance for all projects assigned 

The scope of the IAA is to “provide VA with appropriate resources to assist VA with 

IM/IT program and software program and project management.” This includes support 

services for the following eight general tasks: 

•	 Application Development Assessment 

•	 Program Management and Training & Mentoring 

•	 Workforce Competency 

•	 Service Oriented Architecture 

•	 Program/Project Management 

•	 Information Assurance 

•	 Development and Management of Secure Infrastructure 

•	 IM/IT Project Engineering Assistance 

Although each task in the IAA includes a broad description of the nature of the work to 

be performed, they are not written for a specific project or request for work. 

The IAA is an overarching agreement that does not include a Statement of Work (SOW) 

or specific deliverables. SPAWAR provides the services listed above after receiving a 

formal tasking from VA via a Task Initiation Form (TIF). Under the IAA, VA is 

responsible for issuing the TIF and an accompanying SOW. Once received and accepted 

by SPAWAR, SPAWAR representatives will countersign the TIF and provide a signed 

copy to VA. The IAA requires that in addition to the TIF, each SOW submitted by VA 

will have a designated Point of Contact (POC) identified for the planning and 

implementation of the SOW. The IAA specifies that “development of the TIF, and its 

accompanying SOW, is VA’s opportunity to shape and define the project.” The IAA 

further provides that once collaboration is complete and agreement is reached concerning 

the terms and conditions of the TIF and SOW, resulting project management and 

execution is within the exclusive purview of SPAWAR. 

The IAA sets forth a process for modification of the project identified in the TIF and 

accompanying SOW. The formal stage of this process is required to be accomplished 

and documented through the use of a Project Change Request (PCR) to the existing 

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Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

SOW. The IAA also delineates the requirements for a SOW and a PCR or modified 

SOW. A SOW must include the scope of the tasks, a detailed description of deliverables 

to be produced by SPAWAR, a delivery schedule, major milestones, performance 

measurement parameters, acceptance criteria, estimated total cost for the SOW, and 

security requirements. A PCR or modified SOW is required to change information 

contained within the original SOW including changes to tasking and cost estimates. 

Although there were changes to the projects, no PCRs were issued. 

Although the IAA does not include any specific requirements or deliverables, VA 

obligated and transferred $2.5 million to SPAWAR when the agreement was executed. 

According to the IAA, this was the total estimated funding needed for Fiscal Year 2008. 

Since the agreement was executed in November 2007 funding has increased from $2.5 

million to $66 million. Twenty-two (22) amendments supporting 30 projects have been 

issued. Sixteen (16) of the 22 amendments, totaling $25,695,066, were issued in 

September 2008. Currently, there are 26 projects in the pipeline to be issued which will 

add an additional $73 million to the IAA. VA obligates the funds to the IAA at the time 

each amendment is executed. The amount obligated represents the amount identified in 

the Independent Government Cost Estimate (IGCE) contained in the accompanying 

SOW. These funds are transferred to SPAWAR when the amendment is executed. 

Each amendment to the IAA identifies the number of resources or Full Time Equivalents 

(FTE) required to provide the requested services. The total number of FTE requested by 

VA through Amendment 22 is 295. A resource roster provided by SPAWAR indicates 

that VA funds have been used to purchase the services of 217 FTE of which 22 are 

SPAWAR employees. The remaining FTE are contract employees procured by 

SPAWAR or by SPAWAR contractors through subcontracts. As of March 31, 2009, 

87 percent of the VA funds expended by SPAWAR were for contractor and subcontractor 

effort that includes materials and services. 

On September 11, 2008, the parties executed Amendment 3, which extended the IAA 

through September 2013. Appendix A provides a listing of all projects under 

Amendments 1 through 22 with the project title, period of performance (POP), and 

funding. 

Scope and Methodology 

To address the objectives of this review, we reviewed the IAA, Amendments 1 through 

22, SOW issued thereunder, and information contained in the project managers files as 

provided by OED. We also interviewed the Principal Deputy Assistant Secretary for 

Information & Technology, VA personnel in OED, Office of Acquisition, Logistics, and 

Construction (OAL&C), Office of General Counsel (OGC), SPAWAR, and SPAWAR 

VA Office of Inspector General 3 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

contract employees. In addition, we conducted a site visit to the SPAWAR, South 

Carolina facility to review SPAWAR project manager files, contract documents, funding 

documents, and to hold discussions with SPAWAR management to obtain information 

concerning the SPAWAR management and operation of the IAA. 

VA Office of Inspector General 4 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Results 

We conclude that neither VA nor SPAWAR has complied with the terms and conditions 

of the IAA relating to the administration of the agreement. We also identified two 

amendments that were outside the scope of the IAA as well as work that was being done 

under another amendment that was outside the scope of the amendment. We also 

conclude from that the manner in which the IAA is administered that OED appears to 

have relinquished its responsibilities for program management and support to SPAWAR 

and SPAWAR’s contractors and subcontractors. In addition, because neither VA nor 

SPAWAR has implemented any cost controls, VA may be paying more than necessary to 

obtain the required services. 

Issue 1: Compliance with Interagency Agreement Terms and 

Conditions 

The structure of the IAA requires VA to order work via TIFs and accompanying SOW. 

This has been done by issuing amendments to the IAA. Each Amendment is a standalone 

document in that it should include all documents required by the IAA and documents 

showing that the Amendments reflect the exercising of the contracting officer’s and 

program manager’s fiduciary responsibility. We reviewed the Amendments awarded 

under the IAA, and SOW issued under the Amendments. We also interviewed OED and 

SPAWAR personnel to obtain an understanding of the processes used to award 

amendments. We identified several areas where OED and SPAWAR were not in 

compliance with the terms and conditions of the IAA. 

Determination and Findings 

The IAA states that FAR 17.503 and DFARS 217.504 require that a Determination and 

Findings (D&F) be included as part of the IAA process. Our review of the IAA 

documents disclosed that the D&F signed by the contracting officer to support the use of 

the IAA does address the specific requirements of FAR 17.503 (b), which are: 

If 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; 

VA Office of Inspector General 5 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

(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 

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

purchase such supplies or services on behalf of other agencies. 

In addition, OAL&C was unable to provide documentation to support statements 

included in the D&F. The D&F states that, “Use of an interagency acquisition is in the 

best interest of the Government” and “supplies or services cannot be obtained as 

conveniently or economically by contracting directly with a private source.” OAL&C 

was unable to produce any analysis or other documentation to support these statements. 

OAL&C is also responsible for review of each amendment and the accompanying SOW 

to ensure compliance with applicable laws and regulations. Each amendment bears the 

signature of a contracting officer documenting concurrence. During discussions with the 

contracting officer, we were informed that his reviews of the first 20 Amendments were 

cursory, at best, as his focus was “mission oriented.” We noted, however, that when the 

contracting officer did raise issues on the sufficiency of later amendments, particularly 

the lack of deliverables, he received push-back from OED. In one e-mail, the Deputy 

Chief Information Officer (CIO), OED stated that SPAWAR would cancel all work on 

the project if the amendment was not processed. 

OGC performed a legal sufficiency review of the IAA, including the D&F and all 

amendments. The IAA review in November 2007 included an effective date through 

September 30, 2008, for a total value of $2.5 million. The POP was extended under 

Amendment 3 through September 20, 2013, and the total funding of the IAA through 

Amendment 22 is $66 million. There is no evidence that OGC questioned the 

applicability of the November 2007 D&F that supported use of a $2.5 million agreement 

or the additional $64 million in funding. 

In addition, the OGC attorney who performed the reviews of the IAA and subsequent 

amendments stated the legal sufficiency review included determining whether the 

proposed amendment was within the IAA scope, and that funding was available. Review 

of the SOW is not included for the purposes of determining legal sufficiency. Even with 

this limited review, OGC did not identify that Amendments 10 and 19 contained 

requirements that were outside the scope of the IAA. OGC did not recognize that some 

amendments were really modifications of prior amendments and that it was inconsistent 

with the terms of the IAA to modify amendments in this manner. 

VA Office of Inspector General 6 
 

 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Task Initiation Forms (TIF) 

The IAA states that each formal tasking under the IAA will be accomplished via a TIF. 

The IAA requires that the TIF be prepared by VA. As stated in the IAA, the TIF is the 

VA’s opportunity to shape and define the project. It is to be signed and issued by the VA 

and countersigned by SPAWAR. It must identify the principal participants for both VA 

and SPAWAR, the dollar value of the task, POP, description of the task, and expected 

high level deliverables. Our review disclosed that TIFs were written by SPAWAR, and 

were limited to a project description, task description, and project impact and estimated 

cost statement. VA program officials did not have copies of the TIFs and told us that it 

was SPAWARs responsibility to prepare them. 

Statements of Work 

The IAA specifies that each TIF will be accompanied by a SOW. Although it is VA’s 

responsibility to prepare the SOW, to include an IGCE, for all projects, we concluded 

that SPAWAR and SPAWAR contractors have been primarily responsible for the 

preparation of the SOW. 

Neither OED personnel nor SPAWAR representatives were able to definitively tell us 

who prepared the SOW and both claimed it was a collaborative effort. Discussions with 

OED disclosed that, at most, OED only prepares Section 8 of the SOW which identifies 

task requirements. One SPAWAR representative indicated that SPAWAR assisted VA 

and collaborated in drafting SOW. We were also informed by a VA employee that 

SPAWAR contractors participated in preparing the SOW. Although we could not 

confirm this statement through our interviews, we identified other evidence to support the 

statement. We noted that the cover page on the SOW indicated the SOW was prepared 

by SPAWAR or on behalf of SPAWAR. None of the SOW indicated that they were 

prepared by VA personnel. The cover page for one SOW specifically stated that it was 

prepared by a SPAWAR contractor. In addition to the fact that this is inconsistent with 

the terms of the IAA, contractors who could eventually work under an amendment should 

not be involved in preparing the SOW as it could represent a conflict of interest. 

Although collaboration between OED and SPAWAR to achieve a final SOW is within 

the terms and conditions of the IAA, as the customer, VA should be responsible for 

serving as the lead on writing all SOW. 

We also found that, with few exceptions, the SOW were very broad and general in nature 

and none of them included major milestones that serve to indicate level of progress as 

required by the terms and conditions of the IAA. Although the work was to be paid for 

VA Office of Inspector General 7 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

on a time and materials or cost-reimbursement basis, the SOW did not include the 

number of personnel, qualifications, or hours needed to complete the project. 

The IAA also specifies that SOW will include signatures of the SPAWAR and VA POCs 

to evince that agreement is reached with regard to all SOW terms and conditions. Our 

review disclosed that most SOW did not include signatures. We found that VA POCs 

were not identified at all or were individuals who were not serving in the role as a VA 

program manager for the initiative addressed in the SOW. In one case, when we 

attempted to contact the individual listed as the program manager, we found that he had 

left VA and was working for another agency. When we contacted the individual at his 

new place of work, he told us that he was never the program manager. 

Deliverable Schedules 

The SOW were essentially a boilerplate format that we were told was provided by 

SPAWAR. Section 8 of each SOW, Specific Tasks, was supposed to identify the specific 

requirements for the SOW. Section 10 of the SOW was to identify deliverables and set 

forth a delivery schedule. 

We found several SOW that described deliverables in Section 8 that were not identified 

in the corresponding Schedule of Deliverables contained in Section 10. For example, in 

the SOW for Amendment 21, Chapter 33 Post 9/11 GI Bill, Section 8 identifies the 

following deliverables: 

•	 Enterprise Master Data Management (MDM) Strategy 

•	 Interface Control Documents (ICD) 

•	 Establishment and Operation of a Secure (B2B) Data Connection 

•	 Design, Develop, Implement and Operate an Integrated Data Mart 

•	 Design, develop, and modify interfaces to extract key data from VA legacy 

systems 

•	 Develop a site accreditation package for the installed configuration, suitable for 

incorporation into the System Security Authorization Agreement 

VA Office of Inspector General 8 
  

# DELIVERABLE 

SOW 

REFERENCE DELIVERY DESCRIPTION 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

However, Section 10.1 Deliverable Schedule does not specifically address any of these 

deliverables. It only states the following: 

10.1 Deliverables Schedule

1 

PROJECT MANAGEMENT 

PLAN and PROJECT 

DOCUMENTATION 7.1.6.x 

8.1.1 

Sixty (60) working days after 

receipt of award. Project Management Plan 

Work Breakdown Structure (WBS) 

MONTHLY REPORT 

7.1.6.x 

Initial report: Within forty-five 

(45) business days after award 

Monthly Report: On or before 

the 20th day of the following 

calendar month 

2 Material Purchasing Report 

Monthly Financial Reports 

3 WEEKLY STATUS REPORT / 

Project Status Review 7.1.6.x Weekly basis 

4 Phase-in/Phase-Out 

Transition Plan 7.2 

Within 90 days of notification 

by sponsor that effort has been 

terminated 

The above example shows that even when a report is required, the contents of the report 

are either non-specific or do not address the specific tasks and deliverables. The lack of 

specificity makes it difficult, if not impossible, to monitor performance to ensure VA has 

obtained the services that it has paid for. 

We also found that almost all the Deliverable Schedules in Section 10 of the SOW 

identified deliverables that are only required if requested by the project officer. One 

example, on the next page, is the deliverable schedule from Amendment 11, Data Get 

Well Plan: 

VA Office of Inspector General 9 
 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

# DELIVERABLE SOW REFERENCE 

DELIVERY 

DESCRIPTION 

1 

PROJECT MANAGEMENT 

PLAN and PROJECT 

DOCUMENTATION 7.1.6.x 

8.1.1 

Sixty (60) working days 

after receipt of award. Project Management Plan 

Work Breakdown Structure (WBS) 

MONTHLY REPORT 

7.1.6.x 

Initial report: Within fortyfive (45) calendar days 

after award 

Monthly Report: On or 

before the 20th day of the 

following calendar month 

Material Purchasing Report 

2 Monthly Financial Reports 

3 WEEKLY STATUS REPORT 7.1.6.x Weekly basis 

5 Meeting Minutes 8.1 

Within one (1) calendar 

day after scheduled 

meetings and briefings 

6 Project Status Review 8.1 As needed 

In addition to the fact that there are no requirements that the reports address the tasks 

identified in Section 8 of the SOW, there was a footnote to the requirements for the 

Meeting Minutes and Project Status Review deliverables stating that they were to be 

provided if requested by the Project Officer. 

Identifying deliverables on an “as requested” basis creates an issue relating to the cost of 

the work being procured. The IGCE in the SOW represents the estimate of cost for the 

project, and is the basis for funding by VA. If the cost estimate included time and 

materials needed to prepare these reports and the reports were never required, the costs 

were overestimated. During our review, SPAWAR provided OAL&C with volumes of 

documents including a number of reports that VA personnel in OED did not have. VA 

appears to be paying for deliverables that SPAWAR or SPAWAR contractors prepared 

but VA never requested. We were unable to fully evaluate this issue because there are no 

invoices from SPAWAR or their contractors or subcontractors that associate costs with 

deliverables. VA did not make this a requirement in the IAA, amendments, or SOW. 

Independent Government Cost Estimates (IGCE) 

The IAA requires that each TIF define the dollar value of the task. However, as noted 

above, the TIF is prepared by SPAWAR, not VA. The amendments prepared by VA 

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Review of Interagency Agreement Between the Department of Veterans Affairs 

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contain a dollar amount that is used to fund the amendment. Although not required by 

the IAA, Section 14 of each SOW includes an IGCE. Each IGCE breaks down costs by 

tasks identified in Section 8 and by labor, travel, materials, and project management 

costs. 

Although VA should be preparing the IGCE, no one was able to provide us with any 

documentation showing that the IGCEs were prepared by VA personnel. Based on the 

lack of documentation and our interviews with VA and SPAWAR personnel, we 

concluded that the IGCEs are being prepared by or on behalf of SPAWAR. 

Based on discussions with OED personnel, we learned that VA provides SPAWAR a 

total amount budgeted for each project prior to the development of the IGCE. This 

amount is then used by SPAWAR, or its contractors, to allocate costs to labor, materials, 

travel, and program management for tasks identified in Section 8 of the SOW. 

The IGCE included in the SOW is at a summary level only. There is no breakdown by 

labor categories or hours as usually used to prepare an IGCE. Upon request, SPAWAR 

was able to provide an example of support for their cost estimates that shows hours by 

task and the types of labor categories. We also requested such information from VA 

personnel. VA personnel could not provide any detail support for the IGCE contained in 

each SOW. 

Including hours or skill mix in the IGCE provides a necessary tool for a program 

manager to determine if the proposed hours by labor category meet the tasks as defined in 

the SOW. 

We also found that the costs cited in the IGCE did not always support the corresponding 

task. The following is the IGCE for Amendment 21, Chapter 33 Post 9-11 GI Bill: 

ROM 

Task # Task Title Labor Travel Materials PM Costs1 

Total 

8.1 Project Management and Subject Matter Expertise $2,250,000.00 $120,000.00 $20,000.00 $0 $2,390,000 

8.2 Data Discovery &Documentation Effort $700,000.00 $25,000.00 $12,500.00 $74,200 $811,700 

8.3 Develop and Maintain Interface Control Documents $400,000.00 $0.00 $12,500.00 $74,200 $486,700 

8.4 Establish and Opearte a Secure (B2B) Data Connection $200,000.00 $0.00 $550,000.00 $74,200 $824,200 

8.5 

Design,Develop, Implement and OperateData 

Orchestration $1,500,000.00 $15,000.00 $12,500.00 $74,200 $1,601,700 

8.6 

Design,Develop, Implement and Operate an Integrated 

Data Mart $950,000.00 $15,000.00 $0.00 $74,200 $1,039,200 

8.7 Indentify, Design, Develop and ModifyInterfaces $1,300,000.00 $15,000.00 $12,500.00 $74,200 $1,401,700 

8.8 Interface Testing $745,000.00 $15,000.00 $0.00 $74,200 $834,200 

8.9 Independent Validation and Verification $850,000.00 $0.00 $0.00 $74,200 $924,200 

8.1 Information Assurance and Security $780,000.00 $20,000.00 $0.00 $74,200 $874,200 

8.11 

Procure, Install & Test Hardware & Software for 

SPAWAR Host Site $0.00 $0.00 $1,988,000.00 $74,200 $2,062,200 

1

SPAWAR Program Management Costs: 

Total Cost: $9,675,000.00 $225,000.00 $2,608,000.00 $742,000.00 $13,250,000.00 

VA Office of Inspector General 11 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

The table shows labor costs of $2.25 million for Task 8.1, Project Management and 

Subject Matter Experts. However, a review of Task 8.1 shows that the task is for the 

services of one “seasoned project manager.” Although the Project Manager may utilize 

the services of “other experts when needed,” the SOW does not provide an estimate on 

the number of potential experts, the number of hours their services may be required, or 

the associated fees. The cost of $2.25 million for the services of one individual and 

possibly the services of experts should have been questioned by VA personnel. 

However, the amount was funded by VA when Amendment 21 was executed. 

Subsequent to issuing and funding the amendment, no one in VA has any visibility as to 

how the money was spent. Therefore, no one in VA knows whether the $2.25 million 

was used to fund the Project Manager or whether the services of experts were required. 

Out of Scope Purchases of Equipment and Software 

The scope of the IAA is limited to services. However, Amendments 10 and 19 requested 

SPAWAR to purchase hardware and software, which is outside the scope of the IAA. 

The IAA states that “SPAWARSYSCEN Charleston will provide VA with appropriate 

resources to assist VA with IM/IT program and software program and project 

management. Specific tasks are described within this document.” The specific tasks are: 

• Application Development Assessment 

• Program Management Training & Mentoring 

• Workforce Competency 

• Service-Oriented Architecture 

• Program/Project Management 

• Information Assurance 

• Development and Management of Secure Infrastructure 

• IM/IT Project Engineering Assistance 

The IAA also states that the IAA can be modified by an addendum to the IAA that will be 

attached thereto. However, the scope of the modification must be limited to the purpose 

of the IAA and modifications that exceed the scope are null and void. 

Amendment 10 provided for the purchase of I-Log software licenses to support rulesbased processing of education claims and maintenance of the systems. The SOW stated 

that, “OED engineering has reviewed this product and recommends it for the initial [The 

Education Expert System] implementation.” The purchase of software licenses for VA 

was outside the scope of the IAA, which should have made the Amendment null and 

void. 

VA Office of Inspector General 12 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Amendment 19, OI&T Region 5 Benefits IM/IT Support Projects, provided funding in 

the amount of $14,151,850 for eight additional resources (FTE) to perform the basic eight 

tasks listed in the IAA. The Amendment states that payment will be funded through two 

obligations, the first of which, $4,338,850.00, is for the OI&T Region 5 Benefits IM/IT 

Support projects and includes a list of services. The second obligation, for 

$9,815,000.00, was for the “acquisition and technical refreshment of hardware/software 

materials required in order to deliver secure and cost effective technology services to VA, 

OI&T Region 5 infrastructure.” The Amendment states that this hardware/software may 

include (but is not limited to): Local Area Network (LAN) servers; LAN printers; 

scanners; bar code readers/printers; notebook laptops; Cisco network components, and 

Citrix software licenses.” The inclusion of hardware and software in this Amendment is 

outside the scope of the IAA and should have made the Amendment null and void. The 

fact that the purchase of commodities was outside the scope of the IAA was not 

addressed by OAL&C or OGC during the legal and technical reviews conducted prior to 

executing the Amendments. 

We also noted that the IGCE in the SOW for Amendment 10 showed $1,544,030 for 

procurement of the I-Log equipments and $49,624.31 in program management fees to be 

paid to SPAWAR. Similarly, documentation provided by SPAWAR indicates that VA 

was charged approximately $40,000 for SPAWAR to use its acquisition staff to procure 

the hardware listed in the SOW for Amendment 19. The products purchased under both 

Amendments were standard off-the-shelf commercial products and licenses. If OED had 

requested OAL&C to procure the I-Log software and the hardware and software 

identified in Amendment 19, VA would have saved the $49,624 it paid in program 

management fees to SPAWAR and the $40,000 it paid in acquisition fees. 

With regard to Amendment 19, we also noted that OI&T failed to require SPAWAR to 

comply with VA policy when purchasing the equipment and software. The Amendment 

states: 

In support of this effort OI&T will request SPAWAR to purchase and 

deploy this material. Accordingly, SPAWAR will adhere to VA CIO 

established policy effective June 15, 2007 – VA Use of NASA SEWP IV 

Contracts (WebCIMS 378171) that all VA IT acquisitions (hardware 

and/or software solution) shall be procured utilizing this government wide 

contract. 

This provision required SPAWAR to comply with existing VA policy regarding the 

purchase of IT hardware and software. On June 1, 2007, the former Assistant Secretary 

for Information and Technology issued a memorandum “VA Use of NASA SEWP IV 

Contracts (WebCIMS 378171),” which states that VA offices must use the SEWP IV 

VA Office of Inspector General 13 
 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

contracts for all IT acquisitions. The memorandum provides for waivers to be requested 

through the IT Tracker approval process. 

Amendment 20 to the IAA, Captain James A. Lovell Federal Health Care Project, strikes 

the requirement for SPAWAR to use SEWP. We have not been provided any 

documentation by VA to show that a waiver was processed. According to SPAWAR 

officials, SPAWAR checked with the Assistant Secretary for Information and 

Technology (005) on whether SPAWAR was “required” to use SEWP or to use “the best 

value to the government” approach. SPAWAR stated the determination was to remove 

the VA CIO policy language for purchases made by SPAWAR. Therefore, Amendment 

20 states: “SPAWARSYSCEN Atlantic acquisitions (hardware and/or software) for VA 

shall follow SPAWAR acquisition policies and will be guided by the principle of best 

value to the government.” Amendment 20 was used by SPAWAR to effectively modify 

Amendment 19 and remove the requirement to use the SEWP IV contract for IT 

purchases. 

The use of Amendment 20 to change the terms and conditions of Amendment 19 is 

inconsistent with the terms and conditions of the IAA. Amendment 19 should have been 

modified to remove the restrictions to comply with the June 2007 memorandum issued by 

the Assistant Secretary and a copy of the waiver showing the process was followed 

should have been included in the file. Each amendment is a standalone contract action. 

In addition, there is no documentation in the file showing that this was the best value to 

the Government. 

Performance of Work without Official Authorization 

During our discussions with an OED Program Manager we discovered that it is not an 

unusual practice for SPAWAR to perform work for anticipated projects prior to issuance 

of an amendment or modification to a SOW. For example, we were informed that work 

has begun on the Chapter 33 — Long Term Solution for the Post 9/11 GI Bill. Because 

neither an amendment or SOW were executed for this anticipated project and funds have 

not been obligated, the cost incurred for work performed is being improperly charged to 

Amendment 21 the Chapter 33 —Short Term Solution for the Post 9/11 GI Bill. 

Excess Funding of Amendments 

During our review of the amendments, we noted that Amendments 2 and 3 were 

essentially modifications to Amendment 1. Again, all amendments should be standalone 

documents reflecting new work. Under the terms of the IAA, additional work 

requirements under a previously issued amendment should be processed as modifications 

or PCRs to the amendment and should not be ordered as a new amendment. This resulted 

in the task being overfunded by $664,200. 

VA Office of Inspector General 14 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Amendment 1 was issued on June 2, 2008, for the purpose of providing project 

management and technical services support to VA OED. Specifically, Amendment 1 

requested Project Management Support, Technical Services Support-Common Services 

and Technical Services Support-Scheduling Project. The IGCE included in the SOW for 

Amendment 1 is as follows: 

Task # Task Title Labor Travel Materials Total 

Task 8.1 Project Management $34,000 $6,000 $1,000 $41,000 

Task 8.2 Technical Services - Common Services $351,000 $114,000 $20,000 $485,000 

Task 8.3 Technical Services - Scheduling Project $148,000 $54,000 $10,000 $212,000 

SPAWAR Program Management Costs: 10% $74,000 

Total Cost: $812,000 

ROM 

Amendment 2, issued on July 10, 2008, added Task 8.4 — “Technical Services (HITS) 

Sharing Project.” The costs associated with this task were shown in the IGCE under Task 

8.4 in the amount of $144,320. The IGCE included in the SOW for Amendment 2 is as 

follows: 

Task # Task Title Labor Travel Materials PM Costs1 Total 

Task 8.1 Project Management $34,000 $6,000 $1,000 $4,100 $45,100 

Task 8.2 Technical Services - Common Services $351,000 $114,000 $20,000 $48,500 $533,500 

Task 8.3 Technical Services - Scheduling Project $148,000 $54,000 $10,000 $21,200 $233,200 

Task 8.4 Technical Services - Health IT Sharing (HITS) Project $91,200 $30,000 $10,000 $13,120 $144,320 

1

SPAWAR Program Management Costs: 10% 

Total Cost: $956,120 

ROM 

Tasks 8.1 through 8.3 were identical to those in the IGCE in the SOW for Amendment 1 

except the program management fees that were originally added to the total estimated 

costs of the SOW were now added at the individual task level. 

The SOW for Amendment 3, issued on September 11, 2008, added Task 8.5 for 

“Technical Services Support — Health Information Sharing (HITS) Clinical/Health Data 

Repository (CHDR) Project.” Although the task is defined in Section 8.5 of the SOW, 

the cost associated with Task 8.5 was added to the cost identified for Task 8.4 of 

Amendment 2. The following is the IGCE in the SOW for Amendment 3: 

Task # Task Title Labor Travel Materials PM Costs1 Total 

Task 8.1 Project Management $34,000 $6,000 $1,000 $41,000 

Task 8.2 Technical Services - Common Services $351,000 $114,000 $20,000 $48,500 $533,500 

Task 8.3 Technical Services - Scheduling Project $148,000 $54,000 $10,000 $21,200 $233,200 

Task 8.4 Technical Services - Health IT Sharing (HITS) Project $682,000 $30,000 $35,000 $74,700 $821,700 

1

SPAWAR Program Management Costs: 10% 

Total Cost: $1,629,400 

ROM 

The difference in cost between Task 8.4 in the SOW for Amendment 2 and the SOW in 

Amendment 3 is $677,380. Although the total costs for Amendments 1 through 3 per the 

IGCE in the SOW for Amendment 3 are $1,629,400, our review of VA’s funding 

VA Office of Inspector General 15 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

documents shows that the total funding VA provided to SPAWAR to fund Amendments 

1 through 3 was $2,293,600. VA overfunded the work to be performed on these 

amendments for these tasks by $664,200. 

It is important to note that the SOW and IGCE were prepared by SPAWAR supposedly 

“in collaboration” with VA personnel. In this instance, neither VA personnel nor 

SPAWAR personnel noted the discrepancies in funding nor properly identified the 

additional work in the IGCE. More importantly, neither party complied with the terms of 

the IAA that required such changes to tasks and in cost estimates in a SOW to be done 

via a PCR or modified SOW. Instead these modifications occurred using a series of 

amendments to the IAA and new SOW for each amendment. This example demonstrates 

a deficiency in the administration of the IAA. 

Program Management Support and Labor Costs 

The IAA states that it was entered into under the authority of the Economy Act, 

Title 31 U.S.C. § 1535. Interagency agreements entered into under the authority of the 

Economy Act require full cost recovery to the servicing agency. To comply with the Act, 

the IGCE for each project includes a separately identified Program Management fee 

(PM). SPAWAR was unable to provide documentation supporting the calculation of the 

10 percent PM cost that VA was charged. However SPAWAR representatives identified 

the following types of cost included in the development of the 10 percent factor: 

SPAWAR contracting and financial costs, IAA and administrative costs not associated 

with a specific VA IAA project. We were also informed that the 10 percent is not a fixed 

amount, rather a target. The IAA does not include a fee for PM or any other costs and we 

were not provided any documents showing that PM fees in general or the specific rates 

that VA was to be charged were addressed by the parties prior to executing the IAA. It 

appears that SPAWAR has proposed PM fees in the IGCEs and VA has merely accepted 

what SPAWAR proposed. No OED or OAL&C personnel ever requested SPAWAR to 

substantiate the proposed 10 percent fee. This identifies another weakness in the 

administration of the IAA. 

We also found that SPAWAR is inconsistent in its application of the 10 percent PM fee. 

For example, in Amendment 1, SPAWAR calculated PM fees based on 10 percent of 

labor, material, and travel but in Amendment 19, PM fees were calculated based only on 

labor. We also noted on Amendment 14 SPAWAR did not allocate any PM cost to the 

project. 

We noted that since Amendment 1, there has been no decrease in the rate even though the 

anticipated work under the IAA has grown from $2.5 million to $66 million. Given the 

fact of the substantial increase in work ordered by VA, we would expect that some 

economies of scale would be achieved to decrease the PM fee. 

VA Office of Inspector General 16 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

We were also informed by SPAWAR that labor costs for SPAWAR employees are billed 

at an average rate based upon the employees’ labor classification with the appropriate 

overhead rates and general & administrative rate. The rates charged are in accordance 

with the Navy Working Capital Fund Rates for SPAWAR Charleston as determined by 

the Commanding Officer, SPAWAR, Charleston. The labor costs charged to projects are 

never adjusted to actual cost at the end of the fiscal year. As the Economy Act only 

allows for full cost recovery incurred by the servicing agency, a reconciliation should be 

performed and appropriate adjustment made to costs billed by the servicing agency. 

Appearance of Conflict of Interest 

As previously stated, our review has disclosed that SPAWAR and its contractors play a 

significant role in preparing the SOW and IGCE. The IAA terms and conditions allow 

for SPAWAR to work with VA in determining the final SOW, but the initial SOW must 

be prepared by VA to mitigate appearance of conflict of interest by SPAWAR or its 

contractors. Significant participation by SPAWAR in development of SOW may unduly 

influence the amount of work it and its contractors receive from VA. 

Issue 2: Poor Administration of the IAA 

Lack of Management Oversight by VA Management 

Based on our review of documents provided by OED and interviews and discussions with 

OED personnel, we concluded that OED has not established an oversight process to (1) 

ensure that VA is receiving the best value for its investment, and (2) receiving the 

services and products identified under the IAA. We concluded that OED has essentially 

relinquished its responsibilities to SPAWAR and SPAWAR’s contractors and 

subcontractors. 

OED personnel told us that oversight functions are not being performed by VA. For 

example, neither the Deputy CIO, OED nor anyone else in OED could tell us how many 

FTE were providing services under the IAA, what percentage were Government versus 

contractor personnel, or where they were working, e.g., VA, SPAWAR, or other sites. 

We had to ask SPAWAR to prepare a resource roster for us. Even for those contract 

employees working at VA sites, VA does not monitor the hours worked or verify the 

invoices the contractors submit to SPAWAR, and SPAWAR does not request that VA 

verify hours worked on-site at VA facilities for invoice verification. It is evident from 

our interviews that oversight is viewed as unnecessary because of the Government-toGovernment relationship. We were told that the oversight of the SPAWAR contractor 

personnel performing effort for projects under this agreement is the responsibility of 

SPAWAR. However, for those contractor employees working at VA sites, no SPAWAR 

personnel are present to monitor the level of effort. 

VA Office of Inspector General 17 
 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

When we asked the Deputy CIO, OED what role OED took in the award and 

administration of contracts that SPAWAR awarded to contractors, we were told none. 

He also told us that he learned that some OED personnel were reviewing resumes of 

proposed contractor personnel but that he stopped that practice because this was 

SPAWAR’s responsibility. 

We also learned during our interviews with the Director, Acquisitions Division, OED 

Program Administration Office, that the financial reports that SPAWAR told us they 

provided to the Acquisition Division, OED were not forwarded to OED Program 

Managers or maintained by OED. We were unable to confirm whether anyone in OED 

actually received these reports. 

OED does not maintain a single POC knowledgeable of the administrative aspects of the 

IAA. For example, without the assistance of SPAWAR and SPAWAR contract 

employees, OED was unable to provide the following basic information: 

•	 SOW for all projects initiated 

•	 Listing of VA project managers by project 

•	 The number of DoD contract personnel working on-site at VA locations 

•	 The amount or percentage of work being performed by SPAWAR employees and 

SPAWAR contractors 

•	 Copies of deliverables received (i.e. weekly status reports, monthly financial 

reports 

Throughout our review we experienced great difficulty in obtaining documents and other 

information from OED. Initially, we requested documents from the Chief of Staff, OED 

who was listed as the program manager and point of contact in the IAA. Our request for 

IAA documents was forwarded to the Director, Acquisitions Division, OED, Program 

Administration Office. However, compliance with our request was slow. During a 

subsequent interview with the Deputy CIO, OED, we informed the Deputy of problems 

getting documentation requested and were referred back to the Director, Acquisitions 

Division. Eventually, the Deputy CIO, OED intervened and instituted daily meetings 

with his staff to assist us in obtaining the records needed for the review. 

As previously stated, VA was unable to comply with our requests for information without 

the assistance of SPAWAR personnel. Even with assistance from SPAWAR, producing 

the requested information took a significant amount of time, and produced multiple 

versions of the same documents, none with 100 percent accuracy. For instance, when we 

attempted to contact program managers as listed in the documents provided, we 

discovered some of those individuals were no longer employed at VA. One of the 

program managers listed told us that he was never the program manager for the project. 

VA Office of Inspector General 18 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

When we spoke with the acting program manager, she told us that she was not the 

program manager and also would be leaving OI&T. 

Our review disclosed that during the life of a project, the same project was referred to by 

different names as new versions of the SOW were issued or new amendments were 

established to expand projects under previous amendments. The modification to the 

project names, without documentation contained on the cover page (i.e. formerly XYZ 

Project) or within the SOW, prevents the ability to track the full life of a project. In 

addition, we found that several amendments and/or their corresponding project SOW 

contained requirements that were similar to those in prior amendments and/or SOW. The 

similarity in requirements allows for work to be inappropriately funded by more than one 

amendment. This is illustrated in the monthly financial reports produced by SPAWAR 

containing a Cumulative Funding Profile that identifies each project and the amount of 

funding by amendment number and total funding. We observed that some projects are 

grouped together with funding from multiple amendments being combined to produce 

one grand total funding amount for all three projects. For example, under the SPAWAR 

VA OED Monthly Financial Report (Task 8.8) dated January 2009, Section 1.2 

SPAWAR VA OED Financial Overview/Summary, three projects, (Replacement 

Scheduling Activity —Enrollment System Application (RSA-ESR), Common Services 

09 Bridge (CS), Interagency Identity and Access Management (IAM) [Healthiest 

Technical Services Support (Common Services)]), established under three different 

amendments are grouped together to represent one grand total for funds committed and 

one grand total for funds available. The purpose of this reporting methodology is unclear 

as each project is funded by amendment, and should be tracked by project and 

amendment. This SPAWAR reporting methodology presents the appearance that if funds 

are no longer available under one of the projects included in a grouping, funds from 

another project may be available to continue work. 

As previously discussed, OED is unaware of the cost basis or authority for the SPAWAR 

Program Management fee of approximately 10 percent. The PM fees are just accepted 

without supported justification or written explanation. 

IGCEs are not being prepared in the level of detail that promotes cost control 

management by the VA project managers. Each IGCE is presented at summary level for 

the cost elements: (1) labor, (2) travel, (3) materials, and (4) project management cost. 

The IGCE in the SOW does not provide the labor hours by task or labor categories to 

help facilitate oversight of the amendments. 

VA Office of Inspector General 19 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Inconsistent Statements of Work 

During our review we identified inconsistencies between documentation maintained by 

VA and documentation maintained by SPAWAR. For example, we were provided 

OED’s copy and SPAWAR’s copy of SOW version VA-3.1-00008-08-v1.0 for 

Amendment 22 Interagency Identity and Access Management (IAM) Technical 

Consultation and Engineering Services. A comparison of the documents showed that 

although the SOW version number was identical for both documents, Section 8.0 Specific 

Tasks and Section 10.1 Deliverables Schedule contained different information. 

As another example, we found that Section 8, Table of Contents for Amendment 9, 

contains a listing of tasks that is completely different from the tasks identified in Section 

8 of the SOW. The Table of Contents appears to have been cut and pasted from a 

different Amendment but not revised to be consistent with work being requested in 

Amendment 9. 

SPAWAR provided us with the SOW for Amendment 21, Chapter 33 Post 9/11 GI Bill, 

Technical Consultation and Engineering Services, dated October 22, 2008. The SOW 

version identified on the cover page is identified as VA-OED-8.8.4.2-00008-09-v1.0, 

however, on each following page the version is identified as VA-3.1-80.003-09-v1.0. 

The SOW provided to us by VA for Amendment 21, Chapter 33 Post 9/11 GI Bill, Data 

Integration, Technical Consultation and Engineering Services, dated October 22, 2008 is 

identified as VA-OED-8.8.0-00005-09-v1.0. Although the total estimated amount 

included in Section 14.1, Independent Government Cost Estimate, of both documents is 

the same, the individual cost categories and cost per task do not reconcile. 

Issue 3: Lack of Cost Controls 

As previously discussed, VA failed to implement any cost controls to ensure that it pays 

fair and reasonable prices and that the work is performed. This is evidenced by VA’s 

failure to develop the SOW and the IGCEs, to question the 10 percent PM fees charged 

by SPAWAR, or to be involved in any manner in which the IAA is administered. We 

also concluded that SPAWAR had not implemented any cost controls. 

Because the tasks and deliverables in the Amendments and accompanying SOW were so 

general in nature and we learned that much of the work was contracted out by SPAWAR, 

we expected to find more detailed SOW and deliverables in the contracts or task orders 

awarded by SPAWAR. We also expected that competition would have the effect of 

keeping prices fair and reasonable. 

During our site visit to SPAWAR, we learned that the contracts or task orders were 

issued against existing SPAWAR contracts. There was no competition involved that 

VA Office of Inspector General 20 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

could result in lower prices. We also reviewed the SOW for these contracts and task 

orders and found that they did not identify specific tasks or deliverables. 

During our review of selected contractor invoices (cost reimbursable), we noted that the 

contract and invoices did not contain the indirect rates for billing purposes. In our 

discussions with SPAWAR, we were told that indirect rates are not identified in invoices 

due to concerns over the potential that confidential and proprietary information may be 

accidently disclosed to contractor personnel on site at SPAWAR Charleston. Also, 

SPAWAR stated they rely on DCAA to conduct the final audits of contractor’s indirect 

rates or potentially an adjustment of indirect rates at the end of the contractor’s fiscal 

year. One process of reviewing invoices is to verify that the proper indirect rates were 

billed. Without the indirect rates listed on an invoice or in the contract, one cannot 

determine what indirect rates are being billed. 

Subcontractor Cost and Level of Effort 

Our review disclosed that the majority of services provided by SPAWAR through 

SPAWAR contractors are paid for on a time and material or cost-reimbursement basis for 

actual man hours performed. Each amendment to the IAA includes a number of FTE 

expected to provide services. Based on the resource roster prepared by SPAWAR, as of 

January 2009, there were 195 contractor and subcontractor FTE supporting VA projects. 

Based on our discussions with SPAWAR and review of a contract and task orders issued 

by SPAWAR to contractors under Amendments 1-5, 12, 15, 17-19, 21, and 22, we 

determine that approximately 87 percent of the level of effort performed under this IAA 

is attributed to contractor personnel. In addition, we identified task orders that included 

significant costs that were passed through to subcontractors (second tier contractors). Of 

the 55 task orders we reviewed, we identified 27 (49 percent) that included subcontract 

cost. 

We also noted that some of SPAWAR’s vendors served as prime contractors and as 

subcontractors under the IAA to fulfill VA’s requirements. We asked SPAWAR officials 

to explain their decision to indirectly contract with a vendor who had an established 

prime contract. SPAWAR officials stated that the reason for having a prime contractor 

participate as a subcontractor is due to the ceiling capacity of the prime contractor’s 

contract. Each contract has a ceiling on the amount of services that can be ordered 

through the contract. When the contract’s capacity is no longer available on the contract, 

SPAWAR awards the task order to another prime contractor who subcontracts the work 

to the originally planned contractor. SPAWAR also explained that the labor category 

needed by VA may not be available on the prime contractor’s contract. 

VA Office of Inspector General 21 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

The effects of this type of downstream subcontracting increases costs to VA via increased 

profit and indirect rates for each contractor involved in the process. The prime contractor 

will also incur costs for program management of the task. Prime contractors, when 

including costs proposed by a subcontractor, only show a fully loaded rate, i.e. labor plus 

indirect rates plus profit. SPAWAR lacks privity of contract with subcontractors working 

for SPAWAR’s prime contractors to see the indirect rates and profit used to calculate the 

proposed costs. It is common in Government contracts to pay a fee of 6 to 8 percent on 

cost reimbursable contracts and up to 10 percent on fixed price or fixed rate contracts. 

Our review of selected contracts and task orders issued by SPAWAR indicated that the 

profit/fee charged by prime contractors was approximately 6.5 percent of the prime 

contractor’s cost, which was decreased to 3 percent when they subcontracted the work. 

VA is ultimately charged this 3 percent in addition to the 6 to 10 percent fee that is 

already embedded in the subcontractor costs. As a result, VA is paying at least 3 percent 

higher costs due to high levels of subcontracting. At a maximum, VA could be paying as 

much as 13 percent in fees and profits. 

During our review of contracts used by SPAWAR for the IAA, we noted SPAWAR 

awarded a fixed price labor hour Indefinite Quantity contract on May 20, 2008, to a 

consulting firm. The POP was the date of contract award through one year and contained 

a one-year option period to commence from the date of expiration of the previous 

performance period. On November 3, 2008, more than six months before the base year 

was to expire, the contract was modified to exercise the first option period and to replace 

the POP for option period 1 from November 3, 2008, through November 2, 2009. 

We questioned a SPAWAR contracting officer as to why the option was exercised before 

the end of the base year and why the POP was moved forward to November 2008 from 

May 2009. Since this was a fixed rate contract, we also questioned if the option period 

rates, which were higher, were effective November 2008 instead of May 2009. The 

SPAWAR contracting officer stated the capacity of hours under the base period were 

ordered or planned to be ordered and that since the contract was a fixed rate, the option 

period rates would be effective immediately. 

Exercising the option period prior to May 2009 resulted in increased cost to users of the 

contract and provided additional profit to the contractor. The option period rates are 

higher due to the contractor anticipating higher labor rates in option period 1 originally 

set to start in May 2009. By moving option period 1 rates to November 2008, the 

contractor is billing the higher rates that were not supposed to take effect until May 2009. 

Since these additional costs are ultimately borne by the customer, not SPAWAR, there is 

no incentive for SPAWAR to keep costs down. 

VA Office of Inspector General 22 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Lack of Specificity in Subcontractor’s SOW 

During our site visit to the SPAWAR, South Carolina facility, we reviewed a sample of 

SOW for task orders issued by SPAWAR to contractors who perform services in support 

of the IAA with VA. With few exceptions, we found these SOW to be very broad and 

general in nature and included arbitrary language such as “when requested,” “as 

required,” or “as needed.” 

For example, under the SOW titled, “DCA OED Process Standardization Training,” one 

task states, “As required, the contractor shall support OED Process Management in the 

ongoing alignment of the OED Process Standardization training activities to other 

improvement initiatives.” 

Similarly, under a SOW for System of Systems Project Management Support, the 

following unspecific requirements are identified, “The contractor shall provide technical 

advice and support to the VA SOS Project Manager in the areas of Risk Management,” 

“The contractor shall provide technical advice . . . area of Configuration and Change 

Management,” and “The contractor shall provide technical advice . . . area of Software 

Development Lifecycle Support.” 

Under a SOW titled, “Federal Health Care Center (FHCC) Integrated Information 

Technology (IT) Systems Development,” the SPAWAR contractor is tasked with serving 

as “SPAWAR interface to the customer as needed for development or refinement of these 

requirements and resources,” “shall purchase hardware, software, and tools as required to 

complete the Project Management (PM), requirements gathering, development, and 

testing of the applications.” 

All the SOW we reviewed that were issued by SPAWAR to the contractors include only 

generic deliverables such as conference, meeting minutes, and presentation reports as 

required; technical reports as required; monthly status reports, and monthly financial 

reports. 

Issue 4: Other Matters to be Reported 

Insufficient Legal and Technical Reviews by OAL&C and OGC 

In accordance with VA policy, OED processed the IAA and subsequent amendments 

through the OAL&C and OGC for legal and technical review prior to executing and 

providing final documents to SPAWAR. When we discussed our findings with the 

Principal Deputy Assistant Secretary for OI&T, he raised the issue that the IAA and 

amendments had been reviewed and approved by OAL&C and OGC and stated that he 

VA Office of Inspector General 23 
 

 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

relied on these approvals as an indication that they were legally and technically sufficient. 

Based on his comments, we addressed the issue in our review. 

We found that throughout the process of preparing and awarding amendments, each 

subsequent level of review relied upon the previous level. OGC relied on the contracting 

officer to review the SOW and supporting documentation. OED management relied on 

the contracting officer and OGC’s sign-off on the amendments as acceptance that the 

amendments were accurate and reflected sound contracting procedures. And the 

contracting officer relied on OED for determining that the amendments and 

accompanying SOW accurately reflected VA’s needs. Deficiencies at all these levels 

resulted in the problems identified with the administration of the IAA. 

Coaching & Mentoring 

The Principal Deputy Assistant Secretary of OI&T told us that one of the reasons for 

using the IAA was that OI&T personnel lack skills in managing, cost control, developing 

IT projects, and writing SOW, and the IAA was to help VA personnel develop those 

skills. Based on our review of the IAA, the amendments, and SOW, and the manner in 

which the IAA is administered and on our discussions with VA and SPAWAR personnel, 

VA OI&T employees are not receiving training and mentoring in writing SOW. 

Although coaching and mentoring is being provided in the area of program management, 

we found that training is still needed in the area of writing SOW in order for OED to 

achieve its goal of becoming a high performing performance-based IT organization. 

If OED cannot develop program managers who can write SOW then VA will continue to 

need the services from contractors and will need the services of SPAWAR or other 

contracting entities to issue contracts on their behalf or to off-load contracting work. 

This decreases VA’s ability to properly oversee how its funding is utilized. 

Personal Services 

FAR 37.104 defines a personal services contract as “characterized by the employeremployee relationship it creates between the Government and the contractor’s personnel." 

Paragraph (c) (1) (ii) of FAR 37.104 states that this employer-employee relationship 

occurs when, as a result of “the manner of its administration during performance, 

contractor personnel are subject to the relatively continuous supervision and control of a 

Government officer or employee.” Government contracts for services cannot be for 

personal services absent specific statutory authority. OGC has determined that VA does 

not have this contracting authority. We also understand that SPAWAR does not have 

personal services contracting authority. 

VA Office of Inspector General 24 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

We found that a number of SPAWAR contract employees were working at VA sites 

under the direction of VA employees. We identified instances in which SPAWAR 

contract employees were indentified in the VA Outlook database as being direct reports 

to VA personnel. We also found it difficult to discern between Government employees 

and contract employees during our review. For example, we called a VA employee who 

was identified as a program manager for several amendments to the IAA. His voice mail 

message informed us that he was on travel and if we needed to get in touch with him to 

contact a specific person, whose phone number was provided in the message. We called 

that individual and asked if she could get in touch with the Program Manager and ask him 

to call us. She proceeded to ask a number of questions regarding the reasons we needed 

to speak to the Program Manager. It was only after we told her about the review and the 

information that we sought from the Program Manager that she indicated she was 

associated with SPAWAR as a contractor employee. We found that many of the contract 

employees that we spoke with refer to themselves as a SPAWAR employee. 

To determine VA’s extent of interaction with SPAWAR contractors we conducted 

interviews with contractor employees who were providing services in functions such as 

administrative assistants or special assistants to VA managers and executives. These 

contractors stated they receive their daily tasking directly from the VA employees and 

perform such tasks as preparing memorandums, scheduling meetings, recording minutes 

of meetings, and preparing Congressional correspondence. This was consistent with 

what we were told by the Deputy CIO, OED. We did not see evidence that management 

controls had been established to avoid the performance of inherently governmental 

functions and appearance of personal services. In addition, all of the contract employees 

we interviewed said they had not received training or even been briefed by SPAWAR as 

to what actually is a personal service. We also noted that cubicles occupied by 

contractors did not identify those spaces as belonging to contractors. OED and others in 

OI&T told us that contractor personnel were being used to support OED program and 

operations because OI&T could not hire Government employees because of an FTE 

ceiling. However, no one was able to provide us with more specific information, such as 

a law, regulation, or policy, to explain the basis for the FTE ceiling. 

Lack of Incorporation of Appropriate Security Clauses 

Although the SOW contain requirements for IT security, the task orders we reviewed 

that SPAWAR issued to its contractors did not contain the VA required system security 

and privacy requirement clauses for: Information Security, Cyber Security, and Privacy 

Policy. Absence of these requirements places the VA systems at risk when accessed by 

SPAWAR contractors. We recommend the IAA as well as any task orders issued by 

SPAWAR under this IAA incorporate the VA Information and Information System 

Security/Privacy Requirements for IT Contracts dated August 2008 which states: “All 

VA Office of Inspector General 25 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

contractors and contractor personnel shall be subject to the same Federal laws, 

regulations, standards and VA policies as VA, and VA personnel, regarding information 

and information system security.” 

VA Office of Inspector General 26 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Conclusions and Suggestions 

Based upon our review of the IAA, Amendments 1 through 22, the accompanying SOW, 

and supporting documentation received from OED, OAL&C, OGC and SPAWAR, we 

concluded that: 

•	 The IAA signed in November 2007 and funded in the amount of $2.5 million was 

entered into without an adequate analysis, as required by FAR 17.503, to 

determine that “use of an interagency acquisition is in the best interest of the 

Government,” and that “the supplies or services cannot be obtained as 

conveniently or economically by contracting directly with a private source.” In 

addition, the 22 amendments that provided an additional $63.5 million in funding 

were not supported by additional Determinations and Findings to justify the 

additional use of the IAA for these specific projects. 

•	 OED and SPAWAR failed to comply with terms and conditions of the IAA. The 

problems identified during our review were due in significant part to the fact that 

no one in OI&T or OED appears to be responsible for the administration of the 

IAA or any of the amendments issued against it. These problems were also 

caused by the lack of adequate legal and technical reviews prior to the execution 

of the IAA and the amendments by OGC and OAL&C. 

•	 The terms and conditions of the IAA and the manner in which it has been 

administered resulted in OED having limited participation, ownership, or 

accountability in the planning, development, and the accomplishment of stated 

projects. OED has not implemented any management controls and relies heavily 

on SPAWAR for all management aspects of this IAA. OED appears to have 

relinquished its duties and responsibilities to SPAWAR, only to have SPAWAR 

contract out the work to its contractors. 

•	 SOW and the IGCEs included in the SOW are not prepared by OED but are a 

“collaborative” effort with SPAWAR and SPAWAR contractors. Without a cost 

estimate independently developed by VA, OED cannot determine if the estimate 

of cost prepared by SPAWAR is reasonable. 

•	 OED is not performing sufficient oversight of this agreement to provide 

reasonable assurance that assets are safeguarded against waste, loss, unauthorized 

use, and misappropriation. OED’s view of the IAA is that this is a 

Government -to- Government procurement and SPAWAR has responsibility for 

oversight. 

•	 SPAWAR has not implemented adequate oversight measures or controls to 

protect the interests of the VA. 

VA Office of Inspector General 27 
 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

•	 Purchasing of software and hardware is outside the scope of the IAA. In addition, 

VA incurred increased costs by having SPAWAR use their contracting officers to 

procure the hardware and software instead of OAL&C contracting officers. 

•	 SPAWAR contractors working at VA facilities appear to be providing personal 

services. Neither VA nor SPAWAR has authority to enter into personal services 

contracts. 

We suggest that VA take steps to re-evaluate the IAA and determine whether it is in the 

best interests of VA to continue obtaining services through this type of agreement. If it is 

determined to be in VA’s interest to continue with an IAA to obtain services to support 

OED, we suggest issuing a new IAA that complies with the requirements of Information 

Letter (IL) 001AL-09-04, dated March 23, 2009. The IL establishes VA policy for 

Managing Interagency Acquisitions, and incorporates requirements contained in guidance 

issued by the Office of Federal Procurement Policy in a Memorandum dated 

June 6, 2008, titled “Improving the Management and Use of Interagency Acquisitions.” 

We also suggest that: 

•	 The restructured IAA should emphasize training of VA personnel to better 

manage OED programs and operations and to learn to develop SOW and monitor 

contractor performance. It should also require VA personnel to actively 

participate in the development, award, and administration of contracts to third 

parties to provide services under the IAA. 

•	 OAL&C contracting officers and OGC need to implement processes to improve 

their technical and legal reviews of the IAA, amendments or modifications 

thereto, and the SOW. 

•	 VA should be required to prepare the SOW with specific tasks, deliverables, 

defined delivery dates, and performance measures. 

•	 OED should be required to develop IGCEs as a method of determining the 

reasonableness of proposed cost estimates. The IGCEs should identify labor 

hours and labor categories by task. OED in conjunction with OAL&C should 

determine, on a task basis, whether it is in VA’s best interest to enter into firm 

fixed-price contracts with third parties versus cost-reimbursement or time and 

materials contracts. 

•	 OED should require SPAWAR, or any other Government entity that is party to an 

IAA, to provide financial reports that identify the hours worked by labor category 

and task, and indicate whether the employee is a Government or contract 

employee. 

VA Office of Inspector General 28 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

•	 All amendments and SOW should identify VA program managers who are 

actually performing those duties and responsibilities, and are accountable for the 

outcomes. 

•	 VA should establish policies and procedures for program managers to certify that 

they have reviewed monthly SPAWAR financial documents and progress reports 

and have concurred with them. 

•	 VA should establish a single point of contact within OED to warehouse all 

documents and deliverables required under the IAA and amendments. In 

addition, all VA program managers and project officers should be required to 

maintain all documents provided by SPAWAR under the IAA and Amendments. 

•	 Costs associated with Program Management Support provided by SPAWAR 

should be proposed and reported under a separate amendment. 

•	 VA should cease issuing amendments with multiple unrelated projects and 

multiple amendments for the same project/work. Previously issued amendments 

can be modified to add additional tasks, and such tasks can be tracked and 

reported by SPAWAR. 

VA Office of Inspector General 29 
                  

 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Appendix A 

Projects Identified Under Amendments 1 Through 22 

Amendment Project Period of 

Performance 

Funding 

Initial 

Amendment 

None for Initial Performance 11/7/2007-

9/20/2013 

$2,500,000 

Amendment 1 Technical Services Award Date - 

9/30/08 

$812,000 

Amendment 2 National Health Information Network (NHIN) Award Date - 

9/30/08 

$817,600 

Amendment 3 HealtheVet Application Clinical Data 

Repository/Health Data Repository (CHDR) 

Award Date - 

9/30/08 

$664,000 

Amendment 4 Office of Enterprise Development (OE) 

Improvement Plan 

Award Date - 

9/30/09 

$667,565 

Amendment 4 HeV Life-Cycle Cost Validation 10/1/07 - 9/30/09 $959,640 

Amendment 5 Benefits Delivery Network (BDN) 10/1/07 - 9/30/08 $148,000 

Amendment 5 HealtheVet (Hev) Application System of Systems 

(SOS) 

Award Date - 

9/30/09 

$589,130 

Amendment 5 Clinical Data Repository/Health Data Repository 

(CHDR) Technical Executability Review 

8/13/08-9/30/09 $180,000 

Amendment 5 Pharmacy Technical Executability Review 8/13/08-9/30/09 $180,000 

Amendment 5 Tiger Team Award Date - 

9/30/09 

$336,050 

Amendment 6 Financial and Logistics Integrated Technology 

Enterprise (FLITE) 

10/1/07 - 9/30/08 $775,000 

Amendment 6 Paperless Delivery of Veterans Benefits Award Date - 

9/30/09 

$750,000 

Amendment 6 Bi-Directional Health Information Exchange 

(BHIE) 

Award Date - 

9/30/09 

$658,000 

Amendment 6 VistA Blood Establishment Computer System 

(VBECS) Implementation 

10/1/08 - 9/30/09 $440,000 

Amendment 7 Enterprise Security solution Service Integration 

Test Laboratory 

Receipt of Funds - 

9/30/09 

$1,323,810 

Amendment 8 eBenefits Portal architecture Project Management 

Services 

Award Date - 

9/30/09 

$4,777,788 

VA Office of Inspector General 30 
          

 

 

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Appendix A 

Projects Identified Under Amendments 1 Through 22 

Amendment Project Period of 

Performance 

Funding 

Amendment 9 Office of enterprise Development (OED) 

Improvement Plan 

Award Date - 

9/30/09 

$1,815,000 

Amendment 9 Office of enterprise Development (OED) 

Improvement Plan (HEV RSA SRP) 

Award Date - 

9/30/09 

$1,345,800 

Amendment 10 Education Expert system Acquisition (ILOG) Receipt of Funds 

- 9/30/09 

$1,593,654 

Amendment 11 Data Get Well Plan Award Date - 

9/30/09 

$800,000 

Amendment 12 Service Oriented Architecture Enablement and 

Implementation 

Award Date - 

9/30/09 

$2,100,000 

Amendment 13 Veterans Services Network (VETSNET) 

Technical Services – Batch application Testing 

8/13/08-9/30/09 $707,850 

Amendment 13 Identity Management Award Date -

9/30/09 

$550,000 

Amendment 14 Veterans Services Network (VETSNET) 

Production Support Services 

Award Date - 

9/30/09 

$2,000,000 

Amendment 15 IA Web Portal Award Date - 

9/30/09 

$437,680 

Amendment 16 Processing Modeling Service Center (PMSC) 

(Business Modeling Project) 

Award Date – 12 

months 

$595,380 

Amendment 17 Chapter 33 Program Management 9/1/08 - 9/30/09 $487,000 

Amendment 18 Benefits Program Executive Office Project Award Date - 

9/30/09 

$813,719 

Amendment 19 OI&T Region 5 Benefits IM/IT Support Projects Award Date - 

9/30/09 

$14,151,850 

Amendment 20 Captain James A. Lovell Federal Health Care 

Project 

Award Date - 

9/30/09 

$3,732,177 

Amendment 21 Chapter 33 Post 9/11 GI Bill Award Date -

9/30/09 

$13,250,000 

Amendment 22 Inter-agency Identity and Access Management 

(IAM) 

Award Date - 

9/30/09 

$5,000,000 

VA Office of Inspector General 31 
          

Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Appendix B 

OIG Contact and Staff Acknowledgments 

OIG Contact Maureen Regan 

Acknowledgments Karen Summers 

Debra Allen 

Alan Spitzer 

Michael Bravman 

Carla Vines 

VA Office of Inspector General 32 
Review of Interagency Agreement Between the Department of Veterans Affairs 

and Department of Navy, Space and Naval Warfare Systems Center (SPAWAR) 

Appendix C 

Report Distribution 

VA Distribution 

Office of the Secretary 

Veterans Health Administration 

Veterans Benefits Administration 

National Cemetery Administration 

Assistant Secretaries 

Office of General Counsel 

Non-VA Distribution 

House Committee on Veterans’ Affairs 

House Committee on Appropriations, Subcommittee on Military Construction, 

Veterans Affairs, and Related Agencies 

House Committee on Oversight and Government Reform 

Senate Committee on Veterans’ Affairs 

Senate Committee on Appropriations Subcommittee on Military Construction, 

Veterans Affairs, and Related Agencies 

Senate Committee on Homeland Security and Governmental Affairs 

National Veterans Service Organizations 

Government Accountability Office 

Office of Management and Budget 

This report is available at http://www.va.gov/oig/publications/reports-list.asp 

VA Office of Inspector General 33