Department of Homeland Security
 

Costs Invoiced by McKing Consulting Corporation 


Under Order Number HSFEHQ-05-F-0438 


American Recovery and Reinvestment Act of 2009 

OIG-12-106 July 2012
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington. DC 20528 1 www.oig.dhs.gov 

JUL 30 2012 

MEMORANDUM FOR: Catherine Patterson 

Branch Chief 

Assistance to Firefighters Grants Program Office 

Federal Emergency Management Agency 

FROM: Anne l. Richards ~;('~ Assistant Inspector General for Audits 

SUBJECT: Costs Invoiced by McKing Consulting Corporation Under 

Order Number HSFEHQ·05·F·0438 

Attached for your action is our final report, Costs Invoiced by McKing Consulting 

Corporation Under Order Number HSFEHQ-OS-F-0438. We incorporated the formal 

comments from the Office of Policy and Program Analysis, Federal Emergency 

Management Agency (FEMA) in the final report. 

The report contains three recommendations for FEMA to resolve $154,535 of 

questionable costs and to improve its administration of the contract. The Office of 

Policy and Program Analysis concurred with all recommendations. As prescribed by 

Department of Homeland Security Directive 077·1, Follow·Up and Resolutions for the 

Office of Inspector General Report Recommendations, within 90 days of the date of this 

memorandum, please provide our office with a written response that includes your 

(1) agreement or disagreement, (2) corrective action plan, and (3) target completion 

date for each recommendation. Also, please include responsible parties and any other 

supporting documentation necessary to inform us about the current status of the 

recommendation. Until your response is received and evaluated, the recommendations 

will be considered open and unresolved. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of our report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post 

the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact John E. McCoy II, 

Deputy Assistant Inspector General for Audits, at (202) 254·4100. 

Attachment 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Executive Summary ............................................................................................................ 1 

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

Results of Audit ................................................................................................................... 3 

Staffing Education and Experience ......................................................................... 3 

Storage Costs .......................................................................................................... 4 

Recipient Reporting ............................................................................................... 4 

Recommendations ................................................................................................. 6 

Management Comments and OIG Analysis ............................................................ 7 

Appendixes 

Appendix A: Objectives, Scope, and Methodology ............................................. 9 

Appendix B: Management Comments to the Draft Report .............................. 11 

Appendix C: OIG Analysis of Employees Billed to Task Order Who Did Not Meet 

Education and Employment Experience Standards and McKing 

Comments ..................................................................................... 13 

Appendix D: Major Contributors to This Report ............................................... 19 

Appendix E: Report Distribution ....................................................................... 20 

Abbreviations

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FTE full-time equivalent 

G&A general and administrative 

GSA General Services Administration 

IT information technology 

OIG Office of Inspector General 

OMB Office of Management and Budget 

www.oig.dhs.gov OIG-12-106
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

The Federal Emergency Management Agency (FEMA) awarded a task order to McKing 

Consulting Corporation to assist in administering its grants to firefighters. FEMA 

subsequently modified the order to include the Fire Station Construction Grants 

authorized by the AmericanfRecoveryfandfReinvestmentfActfoff2009, as amended, and 

added $721,000 in funds from the AmericanfRecoveryfandfReinvestmentfActfoff2009, as 

amended, to help finance the modification. The total amount of the task order was not 

to exceed $49,197,425. McKing Consulting Corporation invoiced costs of $42,361,519. 

We conducted our audit to determine whether invoiced costs were allowable, allocable, 

and reasonable according to the task order and applicable Federal requirements. 

We questioned $154,535 paid to McKing Consulting Corporation. We determined that 

costs of $143,173 invoiced for labor were questionable because certain individuals did 

not qualify for the rates at which they were billed. In addition, we concluded that costs 

of $11,362 invoiced for storage exceeded the storage costs incurred by McKing 

Consulting Corporation. Also, we determined that McKing Consulting Corporation 

complied with the AmericanfRecoveryfandfReinvestmentfActfoff2009, as amended, 

requirement for submitting recipient reports; however, the reports included inaccurate 

and unsupported information. 

FEMA agreed with our three recommendations to resolve the questioned costs, 

examine the qualifications of other staff to determine whether billing rates were 

appropriate, and decide whether McKing Consulting Corporation should resubmit its 

final recipient report. 

www.oig.dhs.gov 1 OIG-12-106
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

FEMA awarded a task order, No. HSFEHQ-05-F-0438, to McKing Consulting Corporation 

(McKing) on July 1, 2005, for supervision, labor, equipment, and materials necessary to 

support the fiscal year 2005 Assistance to Firefighters Grant Program and Staffing for 

Adequate Fire and Emergency Response Act Grants. Under this order, McKing technical 

assistance staff supported the FEMA program offices, maintained the program websites, 

developed and distributed educational tutorials, conducted peer review panels, and 

provided administrative and technical support. The order’s period of performance 

included a base year (July 2005 to June 2006) and 4 option years extending through June 

2010. FEMA subsequently extended the period of performance through December 2010. 

The cost ceiling for the order was $49,197,425. McKing invoiced costs of $42,361,519. 

This order was awarded on a time and materials basis. McKing recorded the hours that 

its staff worked on tasks authorized under the order and billed FEMA on negotiated 

rates based on rates published in McKing’s Authorized Federal Supply Services and 

Products Schedule Pricelist (General Services Administration (GSA) Schedule). McKing’s 

GSA Schedule sets forth its job titles, staff descriptions and qualifications, and applicable 

billing rates. The order also authorizes McKing to bill materials at cost plus applicable 

general and administrative (G&A) costs. McKing negotiates G&A rates with the U.S. 

Department of Health and Human Services.

On February 17, 2009, Congress enacted thefAmericanfRecoveryfandfReinvestmentfActf

off2009f(Recovery Act), as amended, which included an appropriation of $210 million to

FEMA for competitive firefighter assistance grants to modify, upgrade, or construct nonFederal fire stations. The Recovery Act authorized FEMA to use up to 5 percent of the 

appropriation for program administration. Using funds from this provision, FEMA 

modified the 2005 task order with McKing to obtain additional program support services 

to accelerate the award of the fire station construction grants. This modification 

(No. P00010) totaled $888,765 and was financed in part with $721,000 of Recovery Act 

funds. With McKing’s assistance, after evaluating approximately 6,000 grant 

applications, FEMA awarded 116 grants totaling $207 million. 

www.oig.dhs.gov 2 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

Of $42,361,519 in invoiced costs, we questioned reimbursement of $154,535, which 

included $143,173 billed for staff who did not qualify for the invoiced rates and $11,362 

in storage costs that exceeded McKing’s incurred costs. McKing complied with 

requirements to submit recipient reports, but the reports included inaccurate and 

unsupported information. 

Staffing Education and Experience 

We questioned $143,173 of labor costs because McKing charged time to the task 

order for certain individuals who did not meet the education and employment 

experience qualifications published in McKing’s GSA Schedule. Included as part 

of the qualifications are the education levels and the employment experience 

required for the positions. McKing billed approximately 220 individuals’ time to 

the task order. 

We reviewed the resumes and personnel file information of 45 individuals 

McKing charged to the task order. We found that McKing billed six (13 percent) 

individuals’ time to staffing categories for which the individuals did not meet the 

education/employment experience standard in McKing’s GSA Schedule (see 

appendix C for our analysis and McKing’s comments). For example, in July 2009 

McKing billed FEMA for a subcontracted Application Programmer-V who did not

meet the labor experience or education requirement in the GSA Schedule. 

According to the schedule, this position requires a bachelor’s degree and 12 

years of experience or a master’s degree and 10 years of experience. The 

individual had an associate’s degree in computer programming and 7 years of 

information technology (IT) experience before coming to work for the 

subcontractor in February 2006. This combination of education and experience 

qualified the individual for the position of Senior Website Developer. For 3 years 

prior to July 2009, McKing charged this individual’s time to the task order as a 

Senior Website Developer. 

A McKing official explained that for a labor category with a bachelor’s degree 

standard, McKing reduces employment experience requirements by 2 years for 

individuals who have a 2-year associate’s degree. The official also said that 

McKing accepts 2 years of college education as equivalent to an associate’s 

degree. We accept the associate’s degree justification because a degree is 

awarded upon completion of a course of study. However, we do not agree that 

2 years of college study equates to an associate’s degree. A degree requires 

www.oig.dhs.gov 3 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

completion of a core curriculum, whereas 2 years of college study may merely 

represent completion of general study requirements. 

According to McKing, FEMA granted a waiver of the GSA Schedule education and 

employment experience requirements. According to a McKing official, staff from 

the prior contract were allowed to work in the same labor category on this task 

order to ensure continuity even if they did not meet the requirements. FEMA’s 

Contracting Officer was unable to locate such a waiver in the contract file. 

Storage Costs 

Under Modification P00007, McKing was to relocate and provide secure storage 

for official grant files offsite for 19 months. McKing proposed and billed rental 

costs for the storage space at $2,523 per month for a total of $47,931. Storage 

space rental is considered a direct cost. For the 19-month period, McKing 

received rental credits and adjustments of $10,260. McKing did not pass on the 

cost savings to FEMA. Additionally, McKing’s G&A costs were charged to the task 

order as a percentage of its other direct costs. As a result, McKing overcharged 

FEMA $1,102 of G&A costs. We questioned the overcharge of $11,362. 

Recipient Reporting 

Section 1512 of Division A of the Recovery Act requires recipients of Recovery 

Act funds to report quarterly to the Federal Government on various data 

elements, such as the amount of funds received, project description(s) and 

status, and an estimate of the number of jobs created and retained. These 

reporting requirements were incorporated into the Federal Acquisition 

Regulation as Subpart 4.15—American Recovery and Reinvestment Act – 

Reporting Requirements. FEMA’s Modification P00012 required McKing to 

follow the Recovery Act reporting requirements. As required, McKing submitted 

reports for the third and fourth quarters of calendar year 2009 and first and 

second quarters of calendar year 2010 and designated the second quarter report 

as its final recipient report. We reviewed 16 data elements from McKing’s 2010 

first and second quarter reports and identified seven exceptions, which are 

discussed below. 

Jobs Reported 

McKing underreported jobs for the first quarter of calendar year 2010 by 4.74 

jobs and over-reported jobs for the second quarter of calendar year 2010 by 1.36 

jobs. McKing representatives said that they reported two jobs each quarter, 

www.oig.dhs.gov 4 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

which represented the two additional staff hired. Office of Management and 

Budget (OMB) criteria state that the number of jobs reported should be 

expressed as “full-time-equivalents” (FTEs), where:

Recovery Act Funded Hours Worked (Qtr n) = FTEs. Hours in a Full-time Schedule (Qtr n) 

Based on submitted billings, we determined that McKing should have reported 

6.74 and 0.64 jobs for the first and second quarters of calendar year 2010, 

respectively. 

Subawards to Organizations/Individuals

McKing personnel incorrectly entered its subagreement with the Cabazon Group 

as a subaward to an individual, which resulted in a duplicate reporting of the 

subagreement. Recovery Act recipient reports include information on the 

number and amount of subawards to organizations and to individuals. The 

reporting tool automatically captures and reports the total number of subawards 

to organizations based on the information entered into the Federal reporting 

website (FederalReporting.gov) by the prime recipient. Recipients are required 

to enter the total number of subawards to individuals into this website. As a 

result, McKing incorrectly reported its subcontract agreement with the Cabezon 

Group as two subcontract agreements. 

Subaward Amount

The amount of McKing’s subcontract agreement with the Cabezon Group was 

incorrectly reported. McKing initially reported $347,216 as the subaward 

amount to the Cabezon Group for both entries. Modification Number 10 to the 

subcontract agreement between McKing and the Cabezon Group increased the 

subcontract agreement amount by $345,709 for fire station construction grant 

peer review support. McKing used Recovery Act funds received from FEMA to 

fund Modification Number 10. McKing identified the error and revised the 

amount under Subaward Amounts to Individuals in its submission of the 2010 

first quarter recipient report, but did not correct the amount in the information 

for its subrecipient organizations submitted to the Federal reporting website. 

www.oig.dhs.gov 5 OIG-12-106
 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Subaward Date

McKing incorrectly reported July 23, 2009, as the subaward date. The effective 

date of Modification Number 10 discussed above is September 28, 2009. 

Required to Report Top Five Highly Compensated Officials

McKing reported “No” to the data element asking whether the prime recipient 

and subrecipients were required to report the names and total compensation of

the top five most highly compensated officials. OMB’s RecipientfReportingfDataf

Model, which expounds the specific data elements that Memorandum 09-21 

requires to be reported, states that the recipient is to report “Yes” if the 

recipient and/or its subrecipients meet specific criteria. McKing representatives 

were unable to provide documentation to substantiate that it did not have to 

report on this data element, and said that it reported “No” because it did not 

have the information available at the time it submitted the calendar year 2009 

third quarter recipient report. 

OMB Memorandum 10-34, UpdatedfGuidancefonfthefAmericanfRecoveryfandf

ReinvestmentfAct, states that the recipient or Federal agency may initiate a 

change to a prior report if the Federal agency determines that the change is 

“material.” The guidance further states that changes to prior reports may not be 

initiated for the “Number of Jobs” field. As a result, McKing can correct the 

errors related to the subaward and requirement to report highly compensated 

officials, but will not be able to correct the “Number of Jobs” errors. 

Recommendations 

We recommend that FEMA’s Contracting Officer:

Recommendation #1:

Resolve the $154,535 of questioned costs. 

Recommendation #2: 

Review the qualifications of the other staff billed by McKing on the task order 

and determine whether additional billing adjustments are warranted.

www.oig.dhs.gov 6 OIG-12-106
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation #3: 

Review McKing’s recipient reporting errors and determine whether a corrected 

final recipient report should be resubmitted. 

Management Comments and OIG Analysis 

FEMA provided formal comments to our draft report, which are included in 

appendix B. 

FEMA Comments to Recommendation #1

FEMA stated that it will “allow McKing Consulting Corporation to return the 

excess funds [$143,173] associated with the employment of staff that did not 

meet the education and employment experience qualifications as published in 

the GSA Schedule.” FEMA also said it will “require McKing Consulting Corporation 

to return the $11,362 in costs billed for grant file storage as McKing received 

rental credits and adjustments but did not pass the costs savings on to FEMA.” 

OIG Analysis

Although concurring with the recommendation, FEMA did not provide an action 

plan including target dates and the names of responsible officials for recovering 

the agreed-upon questioned costs. Therefore, the recommendation is 

unresolved and open. 

FEMA Comments to Recommendation #2

FEMA stated that it will “request that McKing Consulting Corporation provide a 

report on the qualifications of other staff billed on the task order to determine if 

they meet the education and employment experience qualifications.”

OIG Analysis

Although concurring with the recommendation, FEMA did not provide an action 

plan including target dates and the names of responsible officials for completing 

the analysis of qualifications and taking any further corrective actions. 

Therefore, the recommendation is unresolved and open. 

www.oig.dhs.gov 7 OIG-12-106
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA Comments to Recommendation #3

FEMA said that it will request that McKing provide a corrected final recipient 

report. 

OIG Analysis

Although concurring with the recommendation, FEMA did not provide an action 

plan including target dates and the names of responsible officials for obtaining 

the corrected final recipient report. Therefore, the recommendation is 

unresolved and open. 

www.oig.dhs.gov 8 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the HomelandfSecurityfActfoff2002 (Public Law 107-296) by amendment 

to the InspectorfGeneralfActfoff1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

The objective of the audit was to determine whether the costs invoiced by McKing were 

allowable, allocable, and reasonable according to the task order and applicable Federal 

requirements. Our audit covered costs of $42,361,519 for a contractual period July 1, 

2005, to December 31, 2010. Our tests and procedures included the following: 

•	 Reviewing the task order and modifications between FEMA and McKing, the 

Recovery Act, FEMA program guidance, and the Federal Acquisition Regulation 

•	 Interviewing McKing and Cabezon Group officials to obtain an understanding of 

the order’s scope of work and McKing’s accounting processes 

•	 Interviewing FEMA and GSA contracting officials to obtain an understanding of 

the scope of work and GSA Schedule contracts 

•	 Conducting fieldwork at McKing and the Cabezon Group

•	 Examining McKing timesheets, payroll ledgers, accounting documentation, 

vendor invoices, payment documents, and personnel files

•	 Selecting a representative sample of salary and other payments totaling 

$6,602,636 from the 70 invoices submitted by McKing for reimbursement to 

assess eligibility for reimbursement 

•	 Reviewing recipients’ quarterly reports McKing submitted to the Federal 

Government and supporting documentation 

We conducted this performance audit between July 2011 and April 2012 pursuant to the 

InspectorfGeneralfActfoff1978, as amended, and according to generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based upon our audit objectives. We believe that the evidence 

www.oig.dhs.gov 9 	 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

obtained provides a reasonable basis for our findings and conclusions based upon our 

audit objectives. 

www.oig.dhs.gov 10 OIG-12-106
 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

u.s. ~pR rhn~nl of Hom~1D.n<l Sto~u rily 

\VashinI:10J1. DC 20472 

JUN 2 1 <1112 

MEMORANDUM FOR, Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General 

FROIVlo 1"..{)"\-- David 1. Kaufman v\L~ ~ '\5 Director 

FEMA Office of Poli ey and Program Analysis 

SUBJECT, Rcsponse to OIG Draft Rcport, Costs invoiced by Mc.King C011Suiting 

Corporation Under Order Number HSFEHQ-05-F-0138 With the 

Federal Emel-gellcy Mcmagemelll Agency 

The federal Emergency Management Agency (FEMA) appreciates the opportunity to review and 

respond to the Department of Homeland Security (DHS) Office of Inspector General (OIG) Draft 

Report, C(J.<;[s Invoiced by McKi/lg Consulting COIporafion Under Order Nwnber HSFEHQ-05-F0438 With the Federal Emergency Management Age/lCY (OIG Job Code ll-135-AUD-FEMA). As 

noted in our resIXlnses to your recommendations, below, FEMA is continuing to work to resolve the 

issues identified in the audit and we are putting in place a process to avoid similar problems in the 

future. 

Recommendation # 1: Resolve the $ 154,535 of questioned costs. 

FEMA RC5ponse: FEMA concurs wilh this recommendation to resulve the questioned costs of 

SI54,535. Upon review o f the OIG's draft report, FEMA will allow McKing Consulting 

Corporation to return the excess funds associated with the employment of staff that did not meet the 

education and employment experience qualifications as published in the GSA Schedule. FEMA 

concurs with the OIG's determination that 2 years of college study does 110t equate to an associate's 

degree. Based on this detennination, McKing should have charged Q lower fee for the staff 

provided. The lower fee would have resulted in a $143, 173 cost savings. This amount must be 

returned to the federal government. Further, FEMA staff will require McKing Consulting 

Corporation to return the S 11 ,362 in costs billed for grant file storage as McKing received rental 

credits and adjustments but did not P<Jss th e aJst savings on to FEMA. This includes the S 1,102 in 

overcharged General & Administrative costs charged to the task order relatcd to the storage costs. 

Within 30 days of receipt of the final report, FEMA will request that the FEMA Finance Center 

notify the grantee that S I 54,535 is due to the federal government and inform the grantee about 

FEMA 's debt collection procedures. FEMA will also work with its Contracting Officer's Technical 

Representative to implement pro<;edures to prevent similar problems in the future. FEMA requests 

ww ..... fcolUI.,,,,, 

www.oig.dhs.gov 11 OIG-12-106
 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

this recommendation be resolved and open pending implementation of the stated corrective action 

plan. 

Recommendation #2: Review the qualifications of other staff bil1ed on the task order and detennine 

whether additional billing adjustments are warranted. 

FEMA Response: FEMA concurs with this recommendation to review the qualifications of other 

staff billed on the task order to detenninc if they mect the education and employment experience 

qualifications as set forth in the McKing GSA Schedule. 

Within 90 days of receipt of the final report and corrective action plan via the grantee notification 

memorandum. FEMA will request that McKing Consulting Corporation provide a report on the 

qualifications of other staff billed on the task order to detennine if they meet the education and 

employment experience qualifications. FEMA will provide a report to the 010 regarding any 

additional billing adjustments necessary within 30 days of receiving this infonnation from McKing. 

In future contracting, FEMA will request this infonnation prior to award. FEMA requests this 

recommendation be considered resolved and open pending implementation of the stated corrective 

action plan. 

Recommendation #3: Review MCKing's recipient reporting errors and determine whether a 

corrected final recipient report should be resubmitted. 

FEMA Response: FEMA concurs with this recommendation that McKing Consu1ting Corporation 

submit a corrected final recipient report. Within 90 days of receipt of the final report and corrective 

action plan via the grantee notification memorandum, FEMA will request that the grantee provide a 

report. FEMA requests this recommendation be resolved and open pending implementation of the 

stated corrective action plan, 

Again, we thank you for the opportunity to review and comment on the recommendations 

concerning your draft report. Please do not hesitate to contact our Audit Liaison Office point of 

contact, Gina Norton at 202~646w4287. with any questions or concerns regarding our response. 

2 

www.oig.dhs.gov 12 OIG-12-106
 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

OIG Analysis of Employees Billed to Task Order Who Did Not 

Meet Education and Employment Experience Standards and 

McKing Comments

The amount of questioned employee labor costs is summarized below and is followed 

by the basis for each exception. 

Employee Labor Category Amount

Employee 1 Grants Quality Control Specialist-II $51,144 

Employee 2 Administrative Assistant-II 20,909 

Employee 3 Administrative Assistant-II 6,004 

Employee 4 Administrative Assistant-III 20,069 

Statistician-IV 18,734 

Employee 6 Applications Programmer-V 26,313

$143,173

See end of appendix for additional abbreviations. 

Employee Number 1

Labor Category Billed: Grants Quality Control Specialist-I (GQCS-I) 

Education and Employment Experience upon Hiring: The employee was hired in March 

2005 as a Data Entry Specialist and promoted to a GQCS-I in September 2007. Employee 

was a high school graduate and attended college. The employee had 1 year of 

employment experience when hired. 

OIG Analysis: The employee was billed as a GQCS-I in July 2008. Per McKing’s GSA 

Schedule, a GQCS-I will have a bachelor’s degree (BD) with 4 years of experience or a 

high school diploma (HSD) with 8 years of experience. Four years of experience (3 years 

with McKing plus 1 year prior to McKing) at the time of billing did not meet the 8-year 

standard for GQCS-I with HSD. 

McKing Comments: The employee attended 2 years of college prior to being promoted 

to GQCS-I. McKing accepts 2 years of college credits as equivalent to an associate’s 

degree (AD) under its GSA Schedule. An AD is generally considered halfway to a BD, and 

therefore the employment experience under McKing’s GSA Schedule would 

proportionally be lowered to 6 years of employment experience. Even if not initially 

www.oig.dhs.gov 13 OIG-12-106
 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

qualified as a GQCS-I, the employee became qualified for the position in 2010 (6 years of 

employment experience). The employee possess all of the skills necessary to qualify as 

a GQCS-I. 

OIG Response: We do not believe that 2 years of college study should be considered 

equal to an AD because 2 years of college course work may not result in the completion 

of courses necessary for an AD. Therefore, it should not justify a reduction in the 

employment experience standard. Also, while the employee may possess the skills 

necessary to accomplish the tasks, the individual did not meet the qualifications 

established by McKing as necessary for the rate billed. 

Employee Number 2

Labor Category Billed: Administrative Assistant-II (AA-II)

Education and Employment Experience upon Hiring: The employee was hired part time 

in May 2006 as an Administrative Assistant-I. Employee had a HSD and had attended 1 

year of college. Employee’s prior work experience was outdoor summer employment. 

OIG Analysis: The employee was billed as an AA-II in July 2008. Per McKing’s GSA 

Schedule, an AA-II will have an AD with 1 year of experience or an HSD with 4 years of 

experience. The employee with 3 years of experience (2 years with McKing and 1 year 

(3 summers) prior to McKing) at time of billing did not meet the experience standard for 

an AA-II with HSD. 

McKing Comments: An AD is generally considered to be 2 years at a college. The 

employee had completed 11⁄2 years of college credits prior to being billed as an AA-II, 

which McKing considers as three-fourths of an AD under our GSA Schedule. Therefore, 

proportionately, McKing considers 11⁄2 years of employment experience as necessary to 

fulfill the AA-II requirements. The employee was hired as an Administrative Assistant-I 

in May 2006 and promoted to an AA-II in December 2007. McKing considered the 

employee qualified with 11⁄2 years employment experience plus 11⁄2 years college credits. 

OIG Response: We do not believe that attending college for 11⁄2 years should be 

considered three-fourths of an AD because there is no assurance that the courses taken 

would result in any degree. Therefore, it should not justify a reduction in the 

employment experience standard. The employee did not meet the employment 

experience standard at the time of billing.

www.oig.dhs.gov 14 OIG-12-106
 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Employee Number 3

Labor Category Billed: Administrative Assistant-II (AA-II)

Education and Employment Experience upon Hiring: The employee was hired March 

2006 as an AA-II. The employee was a high school graduate and had attended college. 

Employee had 3 years of employment experience when hired. 

OIG Analysis: The employee was billed as an AA-II in May 2006. Per McKing’s Schedule, 

an AA-II will have an AD with 1 year of experience or a HSD with 4 years of experience. 

The employee with an HSD and 3 years of experience did not meet the experience 

standard for an AA-II with an HSD. 

McKing Comments: An AD is generally considered 2 years at a college. Therefore, 

McKing accepts 2 years of college credits as equivalent to an AD under our GSA 

Schedule. At the time the employee was hired as an AA-II in March 2006, the employee 

had attended 21⁄2 years of college. The employee had also worked as an administrative 

assistant with a Federal agency from August 2004 to September 2005, giving the 

employee the requisite 1 year of employment experience. 

OIG Response: As indicated in our analyses above, we do not believe that taking college 

courses should be equated with obtaining a degree, and therefore it should not be used 

as a justification to reduce the employment experience standard. The employee did not 

meet the employment experience standard at the time of billing. 

Employee Number 4

Labor Category Billed: Administrative Assistant-III (AA-III)

Education and Employment Experience upon Hiring: The employee was hired in 

October 2004 as an Administrative Specialist. The employee had an HSD and had 11⁄2 

years of work experience when hired. 

OIG Analysis: The employee was billed as an AA-III in May 2006. Per McKing’s GSA 

Schedule, an AA-III will have an AD with 6 years of experience or an HSD with 9 years of 

experience. The employee had 31⁄2 years of experience (2 years with Cabezon and 11⁄2 

years of prior work experience) at the time of the billing, and therefore did not meet the 

experience standard for an AA-III with an HSD. 

McKing Comments: The employee is a carryover from the previous FEMA contract in 

which the employee was billed as an AA-II. Employee had acquired knowledge of 

www.oig.dhs.gov 15 OIG-12-106
 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

operational procedures and existing administrative support procedures. At the time of 

billing, the employee’s prior experience was considered to provide the agency with a 

level of continuity and inherent understanding of the contract’s administrative 

requirements. Even if not initially qualified as an AA-III, the employee became qualified 

for the position in November 2008 with 9 years of employment experience. 

OIG Response: The employee lacks the requisite number of years of experience to be 

billed as an AA-III. In addition, FEMA’s Contracting Officer was unable to provide a copy 

of the waiver referred to by McKing. 

Employee Number 5

Labor Category Billed: Statistician-IV (S-IV) 

Education and Employment Experience upon Hiring: The employee was hired in May 

2006 as an Administrative/Executive Assistant. The employee had a BD in social science 

and 14 years of experience in general administrative duties when hired. 

OIG Analysis: The employee was billed as an S-IV in December 2010. Per McKing’s GSA 

Schedule, an S-IV will have a BD with 8 years of experience. The employee, with a BD in 

social science, does not in our opinion meet the education requirement. 

McKing Comments: The employee has an HSD and college course work that has 

included relevant subject areas, such as economics, algebra, and information literacy 

research methods. The employee worked at a consulting company for 2 years operating 

as an administrator with duties that included data gathering, report generation, and 

analysis of client information. Employee’s experience supporting government clients 

included the creation of statistical projects such as the development of parity studies. 

The employee’s education and relevant past experience satisfied the requirements of 

the functional needs of the position.

OIG Response: McKing’s GSA Schedule includes three levels of Statisticians: 6, 4, and 3. 

Level 6 has a minimum education requirement of an advanced degree (master’s degree 

or higher), and levels 4 and 3 have a minimum education requirement of a BD. Although 

McKing’s GSA Schedule does not indicate specific majors for its labor categories, it 

describes a McKing statistician as having the academic and practical knowledge to 

(1) determine the mathematical principles involved and the most efficient methodology 

for solutions of problems; (2) act as an adviser or consultant on application of 

mathematical analysis to scientific and engineering problems; (3) gather and analyze 

collected information according to established statistical methods; and (4) prepare 

reports, charts, tables, and other visual aids. In our opinion, the employee did not meet 

www.oig.dhs.gov 16 OIG-12-106
 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

the education standard established by McKing in its GSA Schedule for a midlevel 

statistician. 

Employee Number 6

Labor Category Billed: Applications Programmer-V (AP-V)

Education and Employment Experience upon Hiring: The employee was hired in 

February 2006 as an Applications Developer. The employee had an AD in computer 

programming and had 7 years of IT experience when hired. 

OIG Analysis: The employee was initially billed as a Senior Website Developer, but was 

billed as an AP-V in July 2009. Per McKing’s Schedule, an AP-V will have a master’s

degree with 10 years of experience or a BD with 12 years of experience. The employee, 

with an AD, did not meet the minimum education requirement for an AP-V at the time 

of billing. 

McKing Comments: The employee was billed as a Senior Website Developer in May 

2006. For the Senior Website Developer labor category, the education and employment 

experience is a BD with 4 years of experience or an HSD with 8 years of experience. The 

employee possessed an AD in a related field. An AD is generally considered 2 years at a 

college, halfway to a BD, and therefore the employment experience under McKing’s GSA 

Schedule would proportionally be lowered to 6 years of employment experience. It is 

believed that the employee met the requisite education and experience qualifications 

for the applicable labor category with the employee’s 7 years of experience as noted in 

auditor comments. The employee was also a carryover from the prior FEMA contract in 

which the employee was a Senior Website Developer. FEMA granted a waiver of GSA 

requirements to allow employees to continue serving in the same position as in the 

prior FEMA contract to ensure continuity in the transition between contracts, even if 

they did not meet the GSA labor category requirements. 

OIG Response: We agree that employee qualified as a Senior Website Developer but 

not as an AP-V. Also, FEMA’s Contracting Officer was unable to provide a copy of the 

waiver referred to by McKing.

Abbreviations

AA-II 

AA-III 

AP-V 

AD 

Administrative Assistant-II 

Administrative Assistant-III 

Applications Programmer-V 

associate’s degree 

www.oig.dhs.gov 17 OIG-12-106
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 18 OIG-12-106 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Major Contributors to This Report 

Roger LaRouche, Audit Director 

Jerome Fiely, Audit Manager 

Puja Patel, Program Analyst 

Maureen Duddy, Referencer

www.oig.dhs.gov 19 OIG-12-106
 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs

Assistant Secretary for Office of Legislative Affairs 

Departmental Recovery Act Coordinator 

Administrator, Federal Emergency Management Agency

GAO/OIG Audit Liaison Official, Federal Emergency Management Agency 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 20 OIG-12-106
 
 

ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this document, please call us at (202) 254-4100, fax your 

request to (202) 254-4305, or e-mail your request to our Office of Inspector General 

(OIG) Office of Public Affairs at: DHS-OIG.OfficePublicAffairs@dhs.gov. 

For additional information, visit our website at: www.oig.dhs.gov, or follow us on Twitter 

at: @dhsoig. 

OIG HOTLINE 

To expedite the reporting of alleged fraud, waste, abuse or mismanagement, or any 

other kinds of criminal or noncriminal misconduct relative to Department of Homeland 

Security (DHS) programs and operations, please visit our website at www.oig.dhs.gov 

and click on the red tab titled "Hotline" to report. You will be directed to complete and 

submit an automated DHS OIG Investigative Referral Submission Form. Submission 

through our website ensures that your complaint will be promptly received and 

reviewed by DHS OIG. 

Should you be unable to access our website, you may submit your complaint in writing 

to: DHS Office of Inspector General, Attention: Office of Investigations Hotline, 245 

Murray Drive, SW, Building 410/Mail Stop 2600, Washington, DC, 20528; or you may 

call 1 (800) 323-8603; or fax it directly to us at (202) 254-4297. 

The OIG seeks to protect the identity of each writer and caller.