U.S. COMMODITY FUTURES TRADING COMMISSION

 Three Lafayette Centre

 1155 21st Street, NW, Washington, DC 20581

 Telephone: (202) 418-5110

 

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TO: Heath P. Tarbert, Chairman

 Brian D. Quintenz, Commissioner

 Rostin Behnam, Commissioner

 Dawn Stump, Commissioner

 Dan M. Berkovitz, Commissioner 

 

FROM: Miguel A. Castillo, CPA, CRMA

Assistant Inspector General for Auditing

 

DATE: September 11, 2019

 

SUBJECT: Evaluation: Management of Select Service Contracts Used by the Office 

of Data and Technology (ODT)

Executive Summary

Our objective was to evaluate the management of select service contracts linked to the 

General Services Administration (GSA) Federal Supply Schedule (FSS).

1

 GSA’s FSS 

contracts are indefinite delivery and quantity contracts used extensively by ODT2 to 

acquire essential information technology (IT) services.

3

 

Prior OIG audits have noted that between FY 2011 and FY 2017, Congress annually 

earmarked $35 million to $50 million of CFTC’s total appropriation for IT spending,

4 and

that from FY 2011 through FY 2013, CFTC annually spent 63% of its IT budget on 

service contracts.5 More recently, CFTC obligated $33.7 million in FY 2017 and $34.5 

million in FY 2018 for service contracts, representing 67% and 72% of the total 

authorized budget for ODT, respectively.6 

 

1 GSA FSS satisfy the requirements of the Competition in Contracting Act (CICA) (codified at 41 U.S.C. 

253) and Federal Acquisition Regulation (FAR) Part 5, Publicizing Contract Actions. 2 We identified 128 such contract actions for ODT, and examined them all (see Appx. B). GSA FSS 

contracts are also used extensively by CFTC to support non-ODT operations. 3 An indefinite-quantity contract (FAR 16.504) provides for an indefinite quantity, within stated limits, of 

supplies or services during a fixed period. The Government places orders for individual requirements. 

Funds for the minimum amount of the contract are applied at that the time of award.

4 Audit of CFTC’s Enterprise Architecture Program, December 18, 2017. 

5 Management’s Use of Information Technology Resources in Support of its Strategic Plan and 

Regulatory Responsibilities, October 1, 2014.

6 Between FY 2011 and FY 2018, CFTC’s Congressional appropriation increased from $202,675,000 to 

$249,000,000.
 

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Given the temporary loss of contractors supporting IT security operations due corporate 

acquisition issues7 and FSS contract expiration issues,

8

 we initially focused on related 

service contracts with Phase One Consulting Group, Inc. (Phase One), to determine if 

the events resulted from a systemic contracting weakness or simply an anomalous 

event. Given the weakness identified in procurement communications (Appendix A) and 

the number of ODT FSS contract actions we identified with expiration issues (52)

(Appendix B), we conclude that a systemic issue exists.9 During fieldwork, OGC staff 

opined that certain task order options may be exercised after an FSS contract

expiration. Given the possibility of differing opinions regarding the permissibility of

tasked orders tied to expired FSS contracts,10 we suggest that the CFTC Senior 

Procurement Executive (SPE) and the General Counsel formally evaluate and identify 

any contractual or operational risk emerging from these contract actions. 

Recommendations 

To mitigate future service disruptions, we recommend that CFTC’s SPE in collaboration 

with the General Counsel: 

1. Evaluate the extent and impact of CFTC-wide FSS contract actions that have 

expiration issues in terms of both contract and operational risk. 

CFTC uses the Procurement Information System for Management (PRISM) for 

procurement requisition processing. Our review of the PRISM user-guide revealed the 

system also has the capability to record and track purchase orders and contracts for

procurement life-cycle management. Useful features include contract expiration and 

notification management. As such we also recommend that CFTC:

2. Explore the procurement life-cycle benefits offered by PRISM to automate

workflow communications such as contract expiration notifications. 

 

7 AFS purchased Phase One on August 8, 2017. See (https://www.accenture.com/us-en/insight-phaseone-cut-over). The underlying FSS contract (GS35-F0130U) guiding a CFTC Task Order (CFIT-10-BP0059/2015-002) expired on December 20, 2017. 8 On March 9, 2018, Phase One informed the CFTC CO of its acquisition by FSA and of the FSS contract 

expiration (see fn. 7). GSA did not permit a novation of the contract for AFS because the FSS contract 

had expired, and CFTC therefore could not renew its existing task order before expiration (June 29, 

2018). Consequently, both ODT and the Procurement office swiftly identified suitable replacements. 

Management discovered that due to competitive labor market conditions, one replacement contractor 

could not secure sufficient staff to fully address its commitment to ODT. 

9 We did not review ODT contracts for acquisition issues. 10 Government Accountability Office (GAO) and GSA interpretations appear to be in potential 

disagreement regarding expired FSS contracts. See, GAO opinions AllWorld Language Consultants, 

Inc., Comp. Gen. Dec. B-411481 (Jan. 6, 2016); GBK Partnership, LLC-Constant Associates, Inc., B417039 (Jan 24, 2019); and GSA guidance Contracting Officer Guidance - Schedule Ordering 

Procedures. We therefore recommend this be addressed at higher levels.
 

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Management Response and Evaluation

Management did not concur with recommendation 1 because, after addressing the 

issue at higher levels, including the General Counsel, they concluded that the 

referenced contract actions were proper. Nevertheless, management will assess FSS 

contracts to ensure there are no expiration issues. Management agreed with 

recommendation 2 to explore PRISM communication capabilities and also saw value in 

enhancing instructions to Contract Officer Representatives. 

We consider management planned actions responsive to the findings and 

recommendations in the report. Management’s response is presented in its entirety in 

Appendix D. If you have any questions, please contact me at (202) 418-5084 or Tony 

Baptiste (202) 418-5115. 

Cc: 

Jaime Klima, Chief of Staff 

Kevin S. Webb, Chief of Staff

John Dunfee, Chief of Staff

Daniel J. Bucsa, Chief of Staff

Erik F. Remmler, Chief of Staff

Anthony C. Thompson, Executive Director 

Daniel Davis, General Counsel

John L. Rogers, Chief Information Officer 

Naeem Musa, Chief Information Security Officer

William Roberson, Senior Procurement Executive

Melissa Jurgens, Chief, Executive Secretariat Branch

A. Roy Lavik, Inspector General 

Judith A. Ringle, Deputy Inspector General and Chief Counsel
 

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Appendix A - Communications

Temporary Loss of Contractors Supporting Information Security

IT security operations are handled in ODT’s Policy and Planning Branch (P&PB).

11 

PP&B depends on contractors to identify security risks and perform most IT security 

compliance related tasks.12 The contractors are managed by assigned CORs from 

P&PB. To acquire contract services, ODT management relies on FSS contracts to 

procure services from approved vendors at GSA negotiated labor rates for IT services. 

However, reliance on FSS requires agencies to actively monitor contract terms on both 

the agency task order and the FSS in order to avoid service disruptions experienced by 

security operations due to contract termination events. Events leading to the loss of 

contractor support are chronicled below and depicted in Figure 1. 

• On March 9, 2018, Phase One, an FSS contractor, notified CFTC that it had been 

acquired by Accenture.13 Accenture requested a novation to the existing Phase One 

contract, which GSA would not permit because Phase One’s FSS contract had 

expired.14 CFTC could not novate the FSS contract, as it was a GSA contract, not 

CFTC’s. This circumstance prevented CFTC from exercising an additional option 

period on ODT’s existing task order with Phase One under the FSS (set to expire 

June 29, 2018). Once Procurement15 became aware of the situation, they launched 

a search for an alternate vendor for IT security services.16

• By April 11, 2018, Procurement and ODT identified STG Inc.17 (STG) and directed 

an 8(a) award to XOR as suitable replacements for Phase One. 

 

11 On March 9, 2018, ODT-P&PB staff consisted of four FTEs and 15 contract staff. On March 8, 2019 

P&PB consisted of five FTEs, with contractor staff data not readily available due to unavailability of the 

CFTC staff directory. See CFTC Communication: CFTCnet Staff Directory, April 12, 2019 

(http://cftcnet/Commission/About/Communications/Pages/CFTCnet-Staff-Directory.aspx). 12 Sample of tasks performed are: network configuration management, change management, support 

change control board (CCB), IT security support, A&A support, and Security Impact Analyses. 13 Accenture acquired Phase One in August 2017. 14 CFTC contractual agreements include a clause requiring subcontractors to notify COs of an upcoming 

FSS contract expiration date. This did not happen here. We believe CFTC must monitor FSS expiration 

dates regardless. 

15 The CFTC procurement function (Procurement) resides within the Office of the Executive Director, 

Office of Financial Management. Procurement oversees contracting processes at CFTC. 

16 Staff maintain that, due to performance issues, a change of contractor was desired regardless; 

however, an orderly replacement of contractor would have better served CFTC’s IT needs and probably 

would have avoided additional work required of procurement staff on short notice. 

17 SOS International acquired STG Inc. on April 11, 2018.
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• Since CFTC had an existing Blanket Purchase Agreement (BPA)18 with STG, the

contracting officer (CO) executed a task order on May 31, 2018.19

• On June 1st, transition activities to the new contractor commenced, but by June 29th,

Phase One’s departure date, STG proved unable to acquire sufficient numbers20 of

qualified contractors from the open market or the departing firm to perform security

compliance tasks. A major obstacle was that the new contract firm had lower labor

rates for contractors compared to the prior contractor. Consequently, the Deputy

Director for P&PB decided to delay providing security compliance services

necessary to add devices to CFTC’s IT network.

• On Friday June 29, 2018, the Deputy Director for P&PB informed his ODT

management counterparts21 and the CO that, starting the following Monday, due to

immediately departing contract employees, ODT staff should expect delays in

responding to network security service requests. His email generated a concern that

the transition to a replacement contractor22 for security services had failed. He

characterized this event as a “dire situation.”

18 A BPA is a simplified method of filling anticipated repetitive needs for supplies or services by

establishing “charge accounts’’ with qualified sources of supply (see FAR Subpart 16.7 for additional 

coverage of agreements, https://www.acquisition.gov/far/13.303-1). 

19 Task Order 001 for Configuration Management and IT Security Support Services under BPA CFODT15-BP-0217.

20 See Appendix 6, Table 3 for STG staffing pre and post May 31, 2018.

21 The three are: Deputy Director for Infrastructure and Operations Branch, Deputy Director for Systems and Services Branch, and Deputy Director for Data Management Branch.

22 CFODT-15-BP-0217 executed May 31, 2018 between STG and a CFTC CO; transition activities to

STG commenced June 1, 2018.
 

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Figure 1. Phase 1 Timeline

Weakness in Communication

We acknowledge that ODT and Procurement are currently working effectively to 

address organizational needs for contract services necessary for performing ODT’s 

mission. In addition, we recognize that the Procurement team responded immediately 

to a contracting emergency, i.e., expiration of the underlying FSS; identified alternate 

service providers (STG Inc. and XOR); and promptly executed a replacement contract 

by May 31, 2018. However, in evaluating historical events, we note the potential for 

staff shortages with the new contractor could have been communicated by P&PB before 

the final day (June 29, 2018) of the Phase One contract in order to mitigate the need for 

rationing security services. We interviewed ODT staff attending the management 

meetings and found no evidence of prior dialogue on this issue prior to June 29. 
 

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As presented in Table 1, we examined the replacement contractor’s status report and 

noted that staff shortages were apparent as early as June 8th; one week after onboarding the replacement contractor.

Table 1. Replacement Contractor STG Inc. Staff Provisioning by Week

Week Ending Staff-On 

Site

Inactive 

Staff

Stated 

Vacancy

Hiring In 

Process

Evidence of Staffing 

Shortage

6/1/2018 n/a 0 0 0 Unknown

6/8/2018 n/a 2 0 0 Unknown

6/15/2018 n/a 1 0 0 Unknown

6/22/2018 n/a 0 0 0 Unknown

6/29/2018 n/a n/a n/a n/a Unknown

Source: Weekly Status Reports supplied by STG Inc. 

In addition, we examined the Contracting Officer Representative (COR) designation 

memorandum for emergency or task order expiration communication procedures and 

found none. By including communication responsibilities, CFTC could mitigate the 

failure experienced and all parties affected would be better prepared for any potential 

disruption of service. 

In addition, prudent management mandates that all parties, including COs and CORs,

be aware of upcoming contract end dates for FSS contracts so that mission services are 

not impacted adversely. Given Procurement has deployed PRISM for procurement 

requisitioning, CFTC could automate contract communications and workflow. Our 

research of system functionality identified capabilities for monitoring contract expirations 

and notifications among many other contract administration features. Automating 

contract communications and workflow should be considered given the number of FSS 

contracts ODT relies on and discussed in the next section.
 

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Appendix B – ODT FSS Contract Expiration Issues

Currently, CFTC employs manual procedures for monitoring the expiration date of 

service contracts linked to FSS (agency-wide). At contract issuance, the Procurement 

team relies on the assigned CO to evaluate the accuracy23 of key contract terms such 

as expiration dates for each FSS contract. Additionally, CFTC contractual agreements 

include a clause requiring subcontractors to notify COs of an upcoming FSS contract 

expiration date.24 We believe CFTC is ultimately responsible for monitoring FSS 

contract expiration dates. 

To identify the extent of ODT FSS contract risk based on upcoming expiration dates, we 

examined all active ODT FSS service contracts actions (128). We focused on whether 

the agency sufficiently monitored ODT contract expiration dates in order to avoid 

operational disruptions. For the 128 ODT FSS contract actions during FYs 2017-2018 

reviewed, we found no evidence that the current manual procedure of having the CO 

verify key contract terms (including expiration date of each FSS contract) was not 

performed by a CO. However, we found 3 current ODT contract actions associated with 

FSS contracts that expired in 2012, and 49 ODT contract actions associated with FSS 

contracts that expired in 2017. Given the CFTC currently has 52 ODT contract actions 

that rely on expired FSS contracts, we suggest that the SPE along with the General 

Counsel identify any contractual or operational risk emerging from these contract 

actions.25 For the other FSS expiration years (FY 2019-2022) identified, CFTC should 

take care to ensure sufficient lead time to issue new requests for quotations and select 

replacement contractors, as necessary. 

Table 2. Summary: ODT Contract Actions Associated with Expired FSS Contracts

FSS Expiration Year Count % of Total

2012 3 2%

2017 49 38%

2019 2 2%

2020 38 30%

2021 18 14%

 

23 This internal control task (PM#12) is performed by two procurement staff. A random sample of 45 

contracts was tested for adherence to organizational procedures by the SPE on October 17, 2018. 24 As previously noted, Phase One informed Procurement on March 9, 2018; seventy-nine days after the 

FSS expired. The notification occurred because Accenture Federal Services (AFS), Phase One’s new 

owner, sought a novation. 25 Government Accountability Office (GAO) and GSA interpretations appear to be in potential 

disagreement regarding expired FSS contracts. See, GAO opinions AllWorld Language Consultants, 

Inc., Comp. Gen. Dec. B-411481 (Jan. 6, 2016); GBK Partnership, LLC-Constant Associates, Inc., B417039 (Jan 24, 2019); and GSA guidance Contracting Officer Guidance - Schedule Ordering 

Procedures. We therefore recommend this be addressed at higher levels.
 

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2022 18 14%

Total 128 100%

Table 3. Detail: ODT Contract Actions Associated with Expired FSS Contracts

Contract 

Provider

CFTC File Name GSA# GSA Expiration 

Date

1 Deloitte 

Consulting, LLP Deloitte CFODT-12-BP-0116 ESDS-17 M016 GS-35F-0060L 10-23-12

2 Deloitte 

Consulting, LLP Deloitte CFODT-12-BP-0116-ESDS-17 M014 GS-35F-0060L 10-23-12

3 Deloitte 

Consulting, LLP

Deloitte Consulting CFODT-12-BP-0116 ESDS17 

M013 GS-35F-0060L 10-23-12

4 IBM IBM CFODT-12-BP-0114 SYS-8 M033 GS-35F-4984H 9-30-17

5 IBM IBM CFODT-12-BP-0114 SYS-8 M034 GS-35F-4984H 9-30-17

6 IBM IBM CFODT-12-BP-0114 SYS-8 M035 GS-35F-4984H 9-30-17

7 IBM IBM CFODT-12-BP-0114 SYS-8 M036 GS-35F-4984H 9-30-17

8 IBM IBM CFODT-12-BP-0114 SYS-8 M037 GS-35F-4984H 9-30-17

9 IBM IBM CFODT-12-BP-0114 SYS-8 M038 GS-35F-4984H 9-30-17

10 IBM IBM CFODT-12-BP-0114 SYS-8 M039 GS-35F-4984H 9-30-17

11 IBM IBM CFODT-12-BP-0114 SYS-8 M040 GS-35F-4984H 9-30-17

12 IBM IBM CFODT-12-BP-0114 SYS-8 M041 GS-35F-4984H 9-30-17

13 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 (TO DS-15) 

M022 GS-35F-4506G 4-28-17

14 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 (TO DS-15) 

M025 GS-35F-4506G 4-28-17

15 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 (TO DS-15) 

M026 GS-35F-4506G 4-28-17

16 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 (TO DS-15) 

M027 GS-35F-4506G 4-28-17

17 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 (TO DS-15) 

P00028 GS-35F-4506G 4-28-17

18 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 DMB11 Mod M019 GS-35F-4506G 4-28-17

19 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 DMB11 Mod M021 GS-35F-4506G 4-28-17
 

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Contract 

Provider

CFTC File Name GSA# GSA Expiration 

Date

20 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 DMB11 Mod M022 GS-35F-4506G 4-28-17

21 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 DMB11 Mod M023 GS-35F-4506G 4-28-17

22 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 DMB11 Mod M024 GS-35F-4506G 4-28-17

23 Northrop 

Grumman Northrop Grumman CFODT-12-BP-0111 ES-9B M021 GS-35F-4506G 4-28-17

24 Northrop 

Grumman Northrop Grumman CFODT-12-BP-0111 ES9B M022 GS-35F-4506G 4-28-17

25 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 ES9B 

Mod M018 GS-35F-4506G 4-28-17

26 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 ES9B 

Mod M019 GS-35F-4506G 4-28-17

27 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 ES9B 

Mod M020 GS-35F-4506G 4-28-17

28 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111 PDS-12 

M025 GS-35F-4506G 4-28-17

29 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M023 GS-35F-4506G 4-28-17

30 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M024 GS-35F-4506G 4-28-17

31 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M026 GS-35F-4506G 4-28-17

32 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M027 GS-35F-4506G 4-28-17

33 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M028 GS-35F-4506G 4-28-17

34 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 PDS14 Mod M029 GS-35F-4506G 4-28-17

35 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 SAS13 Mod M022 GS-35F-4506G 4-28-17

36 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 SAS13 Mod M023 GS-35F-4506G 4-28-17

37 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 SAS13 Mod M024 GS-35F-4506G 4-28-17

38 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 SAS13 Mod M025 GS-35F-4506G 4-28-17
 

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Contract 

Provider

CFTC File Name GSA# GSA Expiration 

Date

39 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-12-BP-0111 SAS13 Mod M026 GS-35F-4506G 4-28-17

40 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111-DMB-11 

M020 GS-35F-4506G 4-28-17

41 Northrop 

Grumman

Northrop Grumman CFODT-12-BP-0111-DMB-11 

M020 GS-35F-4506G 4-28-17

42 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0146 MOD 

M006 GS-35F-4506G 4-28-17

43 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0146 MOD 

M007 GS-35F-4506G 4-28-17

44 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0146 MOD 

M008 GS-35F-4506G 4-28-17

45 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0146 MOD 

M009 GS-35F-4506G 4-28-17

46 Northrop 

Grumman NORTHROP GRUMMAN CFODT-15-DO-0233 M004 GS-35F-4506G 4-28-17

47 Northrop 

Grumman NORTHROP GRUMMAN CFODT-15-DO-0233 M005 GS-35F-4506G 4-28-17

48 Northrop 

Grumman NORTHROP GRUMMAN CFODT-15-DO-0233 M007 GS-35F-4506G 4-28-17

49 Northrop 

Grumman NORTHROP GRUMMAN CFODT-15-DO-0233 M008 GS-35F-4506G 4-28-17

50 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0238 MOD 

M004 GS-35F-4506G 4-28-17

51 Northrop 

Grumman

NORTHROP GRUMMAN CFODT-15-DO-0238 MOD 

M006 GS-35F-4506G 4-28-17

52 Northrop 

Grumman Northrop Grumman CFODT-15-DO-0238 P005 GS-35F-4506G 4-28-17

 Source: OFM-Procurement
 

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Appendix C - Objectives, Scope And Methodology

Our objective was to evaluate CFTC’s management of select service contracts linked to 

the General Services Administration (GSA) Federal Supply Schedule (FSS). We initially 

focused on two service contracts supporting IT security operations; Phase One 

Consulting Group, Inc. (Phase One), and Accenture Federal Services (AFS), to 

determine whether a loss of security operations personnel was either a systemic 

contracting weakness or simply an anomalous event. Subsequently, we evaluated all 

FSS contracts ODT uses to determine whether a systemic weakness existed.

We acquired and evaluated a listing of all active ODT service contracts and contract 

actions during Fiscal Year 2017 and 2018 (provided by CFTC’s Office of Financial 

Management Procurement group). We initially focused on contracts with Phase One 

and STG Inc. We did not test the CFTC’s computer generated database for accuracy. 

We also acquired from GSA a copy26 of the related FSS contract issued in 2007. We 

reviewed relevant CFTC contract action items including CFTC’s Blanket Purchase 

Agreement27 issued in 2010 and CFTC-issued task orders linked to the GSA contract.28 

We analyzed the above documents and then interviewed all ODT staff29 who 

participated in management of the contracts. Finally, we gathered weekly status reports 

prepared by the contractors and payment logs. We analyzed all of the acquired 

information and addressed any data discrepancies. We evaluated and included

management comments in our draft. This evaluation was conducted in accordance with 

the Quality Standards for Inspections and Evaluations30 issued by the Council of the 

Inspectors General on Integrity and Efficiency.

 

26 GSA Contract Number: GS35F0130U, period Covered by Contract: 12/20/2007 – 12/19/2017. 

27 CFTC-BPA No CFIT-10-BP-0059 signed 6-30-2010 with Phase One Consulting Group, Inc. specifically 

Task Area 4 –Provide Information Technology (IT) Security Support. 28 The contractor’s GSA Federal Supply Schedule contract number GS-35F-0130U. 

29 CORs, ODT leadership, and ODT staff who interacted with Phase One and STG Inc.. 30 Available at: https://www.ignet.gov/sites/default/files/files/iestds12.pdf. 
 

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Appendix D - Management Response
 

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