GSA Logo - Blue field with white letters and has a star in the center of the 'A' for GSA.

 

 
 


ADMINISTRATOR’S SEMIANNUAL 
MANAGEMENT REPORT TO CONGRESS 

A picture of GSA as seen from E and 19th Streets.

 

REPORT NO. 67 

APRIL 1, 2022 – SEPTEMBER 30, 2022 

 

 

 


 

U.S. General Services Administration 
Robin Carnahan 
Administrator 


Office of the Chief Financial Officer 
Nimisha Agarwal 
Chief Financial Officer 

 

Office of Audit Management and Accountability 
Evan Farley 
Director 


November 2022 
 

This report is in the public domain. Authorization to reproduce it in whole or in part is granted. 
While permission to reprint this publication is not necessary, the citation should be: 

U.S. General Services Administration, Office of the Chief Financial Officer, Office of Audit 
Management and Accountability, Administrator's Semiannual Management Report to Congress, 
No. 67, Washington, DC 20405. 

 

Copies of this report can be obtained using any of the following: 

E-mail: GAO-IGAuditMgmtDiv@gsa.gov 

Online: Semiannual Management Report to Congress 


Contents 
Message from the Administrator ............................................................................................................... 3 
Overview ..................................................................................................................................... 4 
Management’s Response to the OIG Semiannual Report to Congress ............................................................................... 4 
U.S. General Services Administration Organization ............................................................................................ 4 
Audit Follow-up Program ...................................................................................................................... 5 
Organization of Audit Follow-up Program ...................................................................................................... 5 
Agency Audit Follow-up Official .............................................................................................................. 5 
Chief Financial Officer (CFO) ................................................................................................................ 5 
Heads of Services and Staff Offices, Regional Administrators ................................................................................. 5 
Synopsis of Audit Activity ................................................................................................................... 6 
Audits with Disallowed Costs ................................................................................................................. 7 
Audits with Better Use Funds (Potential Cost Savings) ........................................................................................ 8 
Audits under Appeal/Litigation ............................................................................................................... 9 
Contract Audits .............................................................................................................................. 10 
Internal Audits .............................................................................................................................. 11 
Open OIG Recommendations Not Fully Implemented as of September 30, 2022 ...................................................................... 13 
Glossary of Terms ............................................................................................................................ 27 
Appendix ..................................................................................................................................... 29 



Message from the Administrator 

I am pleased to provide Congress with the U.S. General Services Administration’s (GSA) 
Semiannual Management Report to Congress, which summarizes the agency’s audit-related 
actions and accomplishments for the six months that ended September 30, 2022. 

GSA greatly values the contributions of GSA Office of Inspector General (OIG) auditors and takes 
their recommendations seriously. GSA continues strengthening its oversight and has a solid 
commitment to thoughtful and creative solutions that save taxpayer dollars and ensure Federal 
workforce safety. This commitment is reflected in its actions on auditor recommendations and 
many other initiatives. 

GSA looks forward to continued work with GSA’s OIG and Congress to support Government 
responsiveness to American taxpayers. 

Signature - of Robin Carnahan
 


Robin Carnahan 
Administrator 
U.S. General Services Administration 



Overview 

 

Management’s Response to the OIG Semiannual Report to Congress 

This report, GSA's 67th report to Congress since the implementation of the reporting requirement, presents 
management's perspective on audit resolution and follow-up activity for the semiannual reporting period, in 
addition to general statistical summaries. The data in this report indicates that GSA's audit monitoring and 
management activities continue to play a significant and valuable role in the effective management of GSA 
operations, the accomplishment of the Agency mission, and the effective use of taxpayer dollars. 


U.S. General Services Administration Organization 

GSA's Public Buildings Service and Federal Acquisition Service provide Governmentwide delivery of real 
estate, acquisition, and technology services. GSA's Office of Government-wide Policy manages the 
development of specific Governmentwide policies and regulations and provides shared services across 
the Government. GSA's 11 regions provide local support to Federal agencies nationwide, while GSA's 
several staff offices provide support to other GSA organizations, other Federal agencies, and the public. 

The Administrator of General Services directs the execution of all GSA functions. Members of the 
Administrator's office, as well as Regional Administrators and Heads of Services and Staff Offices, advise 
and make recommendations on policy or operational issues of national scope. Heads of Services and Staff 
Offices also are responsible for the execution of programs and services within their offices, under the 
leadership of the Administrator. 

 


 


Audit Follow-up Program 

 
Organization of Audit Follow-up Program 

GSA has effective systems in place for tracking and managing audit recommendations, and enhancement 
and modification of these systems is ongoing. GSA's management is accountable for ensuring prompt, 
appropriate corrective action and works with supervisors and program managers who develop remedies 
from identified findings and report progress in implementing solutions. Agency managers have the 
responsibility to act on the auditor's recommendations, with the audit resolution process overseen by the 
Agency Audit Follow-up Official. The descriptions of the duties of the GSA officials involved in the audit 
follow-up process are below. 


Agency Audit Follow-up Official 

The GSA Deputy Administrator, as the Agency Audit Follow-up Official, has overall responsibility for the 
audit follow-up program. This includes responsibility for ensuring the adequacy of the Agency's follow-up 
system, monitoring the resolution of audit recommendations, and ensuring timely implementation of 
corrective actions. The incumbent in this position also makes final decisions to resolve differences 
between Agency management and the GSA OIG. 


Chief Financial Officer (CFO) 

The CFO provides direction and oversight to the officials in the Office of the Chief Financial Officer 
(OCFO) who manage the GSA's Audit Resolution and Follow-up System. Their responsibilities are as 
follows: 

• Liaise with the GSA OIG and GAO for the coordination of OIG and GAO audits within GSA, and 
coordinate preparation of responses and reports for the signature of the Heads of Service and Staff 
Offices or the Administrator, as required; 
• Ensure timely and effective resolution and implementation of audit recommendations made by the 
GSA OIG and GAO; 
• Ensure agency efficacy in the resolution of findings that cross multiple offices or agencies. 
• Oversee the collection and proper accounting of monetary amounts determined due to the 
Government as the result of audit-related claims; 
• Upon request, review past or present audit recommendations concerning GSA programs; 
• Maintain automated control systems for internal and external audits that provide an accurate 
means for monitoring, analyzing, tracking, and documenting actions taken to implement audit 
recommendations; and 
• Provide analysis to identify trends, minimize repeat findings, and enable preventive action. 


Heads of Services and Staff Offices, Regional Administrators 

Heads of Services and Staff Offices and Regional Administrators to whom audit recommendations pertain 
have primary responsibility for resolving and implementing recommendations promptly, and for the 
following: 

• Ensure controls are implemented to provide timely, accurate, and complete responses to audit 
reports; 
• Develop, advocate, and document agency positions on audit recommendations; 
• Prepare responses to GSA OIG and GAO draft and final reports; 
• Provide comments on audit decision papers prepared by the GSA OIG to accurately state 
management's position on unresolved audit recommendations. 



Synopsis of Audit Activity 

The Inspector General Act of 1978, as amended, requires the Administrator of General Services to report 
directly to Congress on management decisions and final actions taken on audit recommendations made 
by the GSA OIG. 

This report covers the period of April 1, 2022, through September 30, 2022. Included in the report are 
summaries of GSA audit activities concerning: 
 
• GSA implementation of GSA OIG audit report recommendations; 
• Final actions not taken on audits 1 year after the date of the management decision; and, 
• Audit reports and audit actions involving financial recommendations, including disallowed costs, 
funds put to better use (better use funds), or both. 
 
On April 1, 2022, GSA had 53 contract and internal audit reports pending final action. These reports 
contained financial recommendations totaling $14,598,375 (sum of row A, pages 7 and 8). 

• Financial recommendations for 37 contract audits totaled $14,458,319. 
• Financial recommendations for 16 internal audits totaled $140,056. 

Between April 1, 2022, through September 30, 2022, GSA finalized management decisions on 25 audit 
reports concerning nationwide GSA programs and operations. 

• In 18 of the 25 audits, a total of $1,239,833 in pre- and post-award contracts and internal program 
spending identified as having been incorrectly charged to the Government was determined to be 
disallowed costs. 
• GSA OIG recommended in 17 pre-award audits that $127,967,105 could be used more effectively 
if management acted to fully implement and complete GSA OIG’s recommendations (see 
Appendix). 

During this 6-month reporting period, GSA successfully took final action on 27 audits. GSA’s audit actions 
represent the recovery of $7,130,039.88 (row C, page 7) in Government funds and the identification of 
$65,903,173.19 in potential future savings (row C, page 8). 

As of September 30, 2022, GSA had 50 open internal and contract audits, with five audits in litigation.


Audits with Disallowed Costs 

 

Final Action for the 6 Months Ending 

September 30, 2022 

 

A. Audit reports where final action had not been taken 
by the commencement of the reporting period. 

Number of Audit Reports 53
Disallowed Costs $14,598,375.00 


B. Audit reports where GSA/OIG made management 
decisions during the reporting period. 

Number of Audit Reports 25
Disallowed Costs $1,239,833.00 
 

C. Audit reports where GSA took final action during the reporting period.  

Number of Audit Reports 27
Disallowed Costs $7,130,039.88 


(i) the dollar value of disallowed costs $3,675,077.69 

- collections……….…...........................................….$3,675,077.69 

- offset…………….………..............................................$0.00 

- property in lieu of cash…................................…………$0.00 

- surplus……….....….............................................$7.94 

- other…….………….……...………........................................$0.00 

(ii) the dollar value of disallowed costs written off by management. 

 ($3,454,954.25) 

D. Audit reports where GSA did not take final action 
by the end of the reporting period and includes audit 
reports issued during this reporting period. 

Number of Audit Reports 50
Disallowed Costs $8,908,958.00 

 


Audits with Better Use Funds (Potential Cost Savings) 

 

Final action for the 6 Months Ending 
September 30, 2022 

A. Audit reports where final action had not 
been taken by management by the 
commencement of the reporting period. 

Number of Audit Reports 53
No Budget Impact (Actual and Estimated) $337,979,267.19  

B. Audit reports where GSA/OIG made 
management decisions during 
the reporting period 

Number of Audit Reports 25
No Budget Impact (Actual and Estimated) $127,967,105.00 

C. Audit reports where GSA took final action during the reporting period.  

Number of Audit Reports 27
No Budget Impact (Actual and Estimated) $65,903,173.19 
 

(i) the actual dollar value of recommendations that were completed. 

No Budget Impact (Actual and Estimated) $0 

(ii) the actual dollar value of recommendations that management has subsequently concluded should not or could not be implemented or completed. 

No Budget Impact (Actual and Estimated) $0 


(iii) the actual dollar value of recommendations that management has subsequently concluded should not or could not be determined (calculated).

No Budget Impact (Actual and Estimated) $0 


(iv) the estimated dollar value of ''funds to be put to better use'' as agreed to by GSA management and GSA OIG.

No Budget Impact (Actual and Estimated) $0  

D. Audit reports where GSA took no final action by the end of the reporting period and includes audit reports issued during this reporting period. 

Number of Audit Reports 50
No Budget Impact (Actual and Estimated)$592,937,832.00 


Audits under Appeal/Litigation 


Financial recommendations are not included for contract awards or actions that are not completed. 

 

 

Audit Report Number and Name of Contractor 
Issue Date of Report 
Management Decision Amounts of Disallowed Costs 

 

 

A200986P4X21014 
Balfour Beatty Construction, LLC 
2/11/2021 
$0 


A201000P4X21031 
Berkel & Company Contractors, Inc. 
6/9/2021 
$0 



A200997P4X21040 
Kirlin Design Build, LLC 
8/27/2021 
$0

 

A210054P4X22013 
Desbuild EG Management Services JV, LLC 
3/3/2022 
$0 



A220015P4X22028 
At Your Service Companies, LLC 
8/15/2022 
$0 



 


Contract Audits 


Audits with Management Decisions made prior to September 30, 2021, with No 
Final Action as of September 30, 2022 

 

 

Audit Report Number and Name of Contractor 
Issue Date of Report 
Management Decision Amounts of Disallowed Costs 
Reason for No Final Action 

A150001Q2X17033 
Noble Sales Co., Inc. 
3/30/2017 
$285,906 

An investigation was opened by either 
the OIG or the Justice Department 
regarding actions taken by the 
contractor. 


A190070Q4X20035 
KPaul Properties LLC 
5/27/2020 
$133,932 

In the process of collection - GSA is 
collecting funds owed the Government. 


A200959Q3X20038 
Exponent, Inc. 
6/2/2020 
$493,121 

In the process of collection - GSA is 
collecting funds owed the Government. 


A190088Q6X20050 
United Rentals, Inc. 
9/29/2020 
$3,466,171 

Negotiations are proceeding between 
Contracting Officer and contractor. 


A180025Q3X21002 
CSP Enterprises, LLC 
11/2/2020 
$1,311,752 

Negotiations are proceeding between 
Contracting Officer and contractor. 


A200986P4X21014 
Balfour Beatty Construction, LLC 
2/11/2021 
$0 

Litigation in progress. 


A201040Q9X21023 
Invictus International Consulting, LLC 
3/31/2021 
$2,100,090 

Negotiations are proceeding between 
Contracting Officer and contractor. 


A201000P4X21031 
Berkel & Company Contractors, Inc. 
6/9/2021 
$0 

Litigation in progress. 


A200997P4X21040 
Kirlin Design Build, LLC 
8/27/2021 
$0 

Litigation in progress. 


A201024Q5X21044 
Promark Technology, Inc. 
9/17/2021 
$0 

No agreement reached between OIG 
and Contracting Officer on the Decision 
Record. 


A210024Q3X21048 
Slalom, LLC 
9/28/2021 
$ 0 

Negotiations are proceeding between 
Contracting Officer and contractor. 


A201025Q5X21049 
Hyland Software, Inc. 
9/30/2021 
$ 0 

Negotiations were completed between 
Contracting Officer and contractor. 

 


Internal Audits 
Audits with Management Decisions made prior to September 30, 2021, with No Final Action as of September 30, 2022 

Audit Report Number and Title of Report 
Issue Date of Report 
Management Decision Amounts of Disallowed Costs 
Reason for No Final Action 
Projected Completion Date 


A180073P2R19006 
GSA's Northeast and Caribbean Region Lacks Policies and Procedures for Emergencies and Evacuations in Puerto Rico 
6/19/2019 
$11,930 

Recovery of funds underway, pending closure 


A190016ITF21002 
Audit of GSA's Insider 
Threat Program 
2/17/2021 
$0  
Audit is in Implementation 
10/31/2022 


JE21-001 
OIG EVALUATION REPORT: GSA's National Capital Region Internal Fleet is Underutilized 
2/25/2021 
$0 
Audit is in Implementation 
10/31/2022 


JE21-002 
OIG EVALUATION REPORT: Evaluation of the General Services Administration's Use of an Ad Hoc Appraisal Process for an Executive 
9/14/2021 
$0 
GSA and GSAIG are working to develop and approve a resolution plan 

 

A201011PRR21006 
Audit of PBS Lease Administration 
9/21/2021 
$0 
Audit is in Implementation 
10/31/2022 



A201020P9R21008 
Opportunities for PBS to Improve Management and Oversight of Its Federal Aggregated Solar Procurement Pilot Contracts 
9/30/2021 
$128,126 
Implementation completed, pending closure 
10/5/2022 




Internal Audits (cont.) 
Audits with Management Decisions made prior to September 30, 2021, with No Final Action as of September 30, 2022 

Audit Report Number and Title of Report 
Issue Date of Report 
Management Decision Amounts of Disallowed Costs 
Reason for No Final Action 
Projected Completion Date 

JE21-003 
Unrestricted Summary: Facility Inspection of a High-Risk GSA Building 
9/30/2021 
$0 
Audit is in Implementation 
10/31/2022 




 

 


Open OIG Recommendations Not Fully Implemented as of September 30, 2022 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation 


A190016ITF21002 
Audit of GSA's Insider Threat Program 
2/17/2021 
001A 
Establish effective controls to enhance cross-
organizational communication and 
collaboration with the ITP by re-establishing 
consistent group collaboration with OHRM, 
Office of GSA IT, OCFO, OMA, and other 
relevant offices to consult on broader, non-
case-specific, insider-threat-related issues. 
Original due date: 1/31/2022 
Current due date: 10/31/2022 

002A 
Establish effective controls to enhance 
oversight of the employee separation and 
termination processes by establishing 
procedures that ensure the ITP is informed 
and aware of insider threat risks posed by 
separated and terminated employees. 
Original due date: 1/31/2022 
Current due date: 10/31/2022 



JE21-001 
OIG EVALUATION 
REPORT: GSA's National 
Capital Region Internal 
Fleet is Underutilized 
2/25/2021 
002 
Evaluate the Executive Driver Program current 
usage against commercially available 
transportation sources and rates to balance 
needs and achieve cost savings beneficial to 
the Government. 
Original due date: 2/28/2022 
Current due date: 10/31/2022 

 
A201011PRR21006 
Audit of PBS Lease 
Administration 
9/21/2021 
002A 
Review, update, and provide adequate LAM 
training. Update the Lease Management Desk 
Guide chapter on training to require annual 
training for LAMs in inspections and lease 
management. 
Original due date: 10/31/2022 
Current due date: 10/31/2022 

 

JE21-003 
Unrestricted Summary: 
Facility Inspection of a 
High-Risk GSA Building 
9/30/2021 
001A 

Recommendations and dates are not 
available to the public. 




Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation 

A190054P4R22001 
Audit of a Hotline 
Complaint: PBS Greater 
Southwest Region's 
Operations and 
Maintenance Contracts 
12/16/2021 
002A 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when procuring O&M contracts, ensure 
price reasonableness by using price analysis 
techniques recommended by the FAR, such as 
evaluating labor equipment and material, and 
subcontractor cost categories of price proposals. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

002B 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when procuring O&M contracts, ensure 
price reasonableness by ensuring independent 
government estimates (IGE) are prepared using 
detailed analysis of the required work, including 
appropriate staffing levels and labor rates, 
equipment and material costs, and subcontractor 
costs. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

003A 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when administering O&M contracts, 
ensure consistent application of the O&M contract's 
shared liability clause and seek approval from 
contracting officers prior to requesting additional 
services work orders. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

 

 

 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 


A190054P4R22001 
Audit of a Hotline 
Complaint: PBS Greater 
Southwest Region's 
Operations and 
Maintenance Contracts 
(continued) 
12/16/2021 
003B 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when administering O&M contracts, follow 
contract terms and conditions for costs related to 
additional services performed, including the 
application of overhead on subcontract labor and 
reimbursement of contract labor for personnel to 
escort subcontractors. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

003C 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when administering O&M contracts, 
enforce staffing-level requirements in O&M contracts 
and ensure consistent interpretation of prescriptive 
and performance-based contract language. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

003D 
OIG recommends that the Greater Southwest PBS 
Regional Commissioner review current Operations 
and Maintenance (O&M) contracts and develop and 
implement policies for current and future O&M 
contracts when administering O&M contracts, 
develop detailed quality assurance surveillance 
plans (QASP) and perform and track quality 
assurance and building inspections in accordance 
with PBS policy and contract terms and conditions. 
Original due date: 12/15/2022 
Current due date: 12/15/2022 

 




Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation

A190043P4R22002 
Audit of PBS's 
Management of Asbestos 
at the Chet Holifield 
Federal Building in 
Laguna Niguel, California 
2/3/2022 
001A 
PBS Regional Commissioner of the Pacific Rim 
Region develop and implement internal controls to 
ensure adherence to federal and state regulations 
and PBS policy for asbestos management. These 
controls should ensure that PBS develops and 
maintains an accurate, current, and complete Chet 
Holifield Federal Building (CHFB) asbestos-
containing materials (ACM) inventory. 
Original due date: 1/31/2023 
Current due date: 1/31/2023 

 
A210020P6R22003 
PBS Has Not Identified 
All High-Risk Uses of 
Space, Resulting in 
Potential Safety Risks 
3/24/2022 
001 
PBS Commissioner revise and strengthen the space 
evaluation policy, including the permit referenced in 
"Appendix B. GSA Fire, Safety and Health (FSH) 
Program Potentially High Risk Use Permit," by using 
plain language and better defining policy terms and 
conditions. 
Original due date: 5/31/2022 
Current due date: 3/24/2023 

003 
PBS Commissioner develop and implement a 
centralized tracking mechanism for all high-risk use 
space types in the PBS Real Estate across the 
United States (REXUS) system. 
Original due date: 12/30/2022 
Current due date: 12/30/2022 

004 
PBS Commissioner provide formal, standardized 
training to the Office of Facilities Management, the 
Office of Portfolio Management and Customer 
Engagement, and the Office of Leasing regarding 
the space evaluation policy and the offices' 
respective roles and responsibilities. 
Original due date: 5/31/2022 
Current due date: 3/24/2023 

 

 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation

A210020P6R22003 
PBS Has Not Identified All 
High-Risk Uses of Space, 
Resulting in Potential 
Safety Risks 
(continued) 
3/24/2022 
005 
PBS Commissioner revise and strengthen the space 
evaluation policy, including the permit referenced in 
"Appendix B. GSA Fire, Safety and Health (FSH) 
Program Potentially High-Risk Use Permit," by using 
plain language and better defining policy terms and 
conditions. 
Original due date: 12/30/2022 
Current due date: 12/30/2022 

 

A210018PTR22004 
Audit of the Security 
Controls for Building 
Automation Technologies 
in GSA Facilities 
4/22/2022 
001 
PBS Commissioner, in coordination with the GSA 
Chief Information Officer, implement controls to 
ensure that GSA building automation technology 
vulnerabilities are remediated within the time limits 
required under GSA's IT Security Procedural Guide: 
Managing Enterprise Cybersecurity Risk, CIO-IT 
Security-06-30. 
Original due date: 2/28/2023 
Current due date: 2/28/2023 

002 
OIG recommends the PBS Commissioner, in 
coordination with the GSA Chief Information Officer, 
implement controls to ensure that Building Systems 
Network (BSN) laptops are configured in 
accordance with GSA's IT Security Procedural 
Guide: Windows 10 Hardening, CIO-IT Security-16-
74; and the GSA Microsoft Windows 10 Security 
Benchmark. 
Original due date: 3/30/2023 
Current due date: 3/30/2023 

003 
PBS Commissioner, in coordination with the GSA 
Chief Information Officer, implement controls to 
ensure that procedures for deviation approvals are 
followed in accordance with GSA's IT Security 
Procedural Guide: Windows 10 Hardening, CIO-IT 
Security-16-74. 
Original due date: 2/28/2023 
Current due date: 2/28/2023 


 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 


A210018PTR22004 
Audit of the Security 
Controls for Building 
Automation Technologies 
in GSA Facilities 
(continued) 
4/22/2022 
004 
PBS Commissioner, in coordination with the GSA 
Chief Information Officer, implement controls to 
ensure that conditions identified in the Acceptance 
of Risk letters are tracked and remediated within 
the time limits specified and in accordance with 
GSA's IT Security Procedural Guide: Managing 
Enterprise Cybersecurity Risk, CIO-IT Security-06-30. 
Original due date: 3/30/2023 
Current due date: 3/30/2023 

005 
PBS Commissioner, in coordination with the GSA 
Chief Information Officer, implement controls to 
ensure that data currently maintained in the 
National Computerized Maintenance Management 
System inventory is accurate and complete. 
Original due date: 3/30/2023 
Current due date: 3/30/2023 

007 
OIG recommends the PBS Commissioner, in 
coordination with the GSA Chief Information Officer, 
implement controls to ensure that the National 
Computerized Maintenance Management System 
data is consistently monitored for accuracy and 
completeness and guidance for doing so is clearly 
defined across GSA policies, procedures, and 
guidance. 
Original due date: 3/30/2023 
Current due date: 3/30/2023 

 

A190100P5R22005 
Audit of PBS's Approval 
Process for Minor Repair 
and Alteration Projects 
5/9/2022 
001 
PBS Commissioner conduct a comprehensive 
assessment to determine if a centralized approval 
process is the most effective way for the Agency to 
ensure its limited funding is directed to the most 
critical needs of its buildings. 
Original due date: 10/31/2022 
Current due date: 10/31/2022 

002A 
PBS Commissioner improve PBS's use of its 
Decision Lens software if the assessment shows 
that a centralized approval process is most 
effective. Improvements should include providing 
guidance for selecting program areas. 
Original due date: 10/31/2022 
Current due date: 10/31/2022 



Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Cited Recommendation 

A190100P5R22005 
Audit of PBS's Approval 
Process for Minor Repair 
and Alteration Projects 
(continued) 
5/9/2022 
002B 
PBS Commissioner improve PBS's use of its 
Decision Lens software if the assessment shows 
that a centralized approval process is most effective. 
Improvements should include assessing whether to 
incorporate additional criteria. 
Original due date: 10/31/2022 
Current due date: 10/31/2022 

002C 
PBS Commissioner improve PBS's use of its 
Decision Lens software if the assessment shows 
that a centralized approval process is most effective. 
Improvements should include ensuring all changes 
to Decision Lens criteria and 
weights are documented. 
Original due date: 10/31/2022 
Current due date: 10/31/2022 


A210033P5R22006 
Audit of Security Camera 
and Alarm Systems at 
GSA-Owned Buildings 
6/22/2022 
001A 
In conjunction with the U.S. Department of 
Homeland Security's Federal Protective Service 
(FPS), conduct a nationwide assessment of GSA-
owned buildings to identify degraded, inoperable, 
and deficient security camera and alarm systems. 
Original due date: 6/30/2023 
Current due date: 6/30/2023 

001B 
In conjunction with the U.S. Department of 
Homeland Security's Federal Protective Service 
(FPS), develop and implement a plan to repair, 
replace, and install the security camera and alarm 
systems identified through the nationwide 
assessment. 
Original due date: 6/30/2023 
Current due date: 6/30/2023 

001C 
In conjunction with the U.S. Department of 
Homeland Security's Federal Protective Service 
(FPS), revise GSA's Memorandum of Agreement 
(MOA) with FPS to clearly define responsibility for 
repairing and replacing security camera and alarm 
systems within an acceptable time frame. 
Original due date: 12/30/2022 
Current due date: 12/30/2022 




Open OIG Recommendations Not Fully Implemented (cont.) 
Audits with Management Decisions and Approved Due Dates 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation 

A210033P5R22006 
Audit of Security Camera 
and Alarm Systems at 
GSA-Owned Buildings 
(continued) 
6/22/2022 
002 
In conjunction with FPS, GSA is not able to secure 
funding to repair, replace, or install security camera 
and alarm systems, GSA should work with Congress 
to establish a consistent funding stream to address 
current and future security camera and alarm 
system deficiencies. 
Original due date: 6/30/2023 
Current due date: 6/30/2023 

 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses Awaiting OIG Feedback 
 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation 

JE21-002 
OIG EVALUATION 
REPORT: Evaluation of 
the General Services 
Administration's Use of 
an Ad Hoc Appraisal 
Process for an Executive 
9/14/2021 
001 
Take appropriate action to remedy the harm caused 
by a tainted performance review process that 
resulted in an unsatisfactory rating and in her 
removal from the Associate Administrator position, 
as well as the loss of any opportunity for a FY 2017 
performance period pay increase or bonus. 

002 
Review current processes and procedures to ensure 
sufficient oversight of employee misconduct and 
disciplinary reviews, including timely referral to the 
OIG. 



 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses in Development 

 
Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation

A201045Q3P22001 
FAS's Use of the 4P 
Tool on Contract and 
Option Awards Often 
Results in Noncompliant 
Price Determinations. 
7/27/2022 
001 
Develop and implement oversight controls to 
ensure contracting personnel adhere to FAS 
Policy and Procedures 2020- 02 and 2021-05, 
and only use the 4P tool as part of a larger 
negotiation strategy that seeks the lowest overall 
cost alternative to meet the needs of the federal 
government, as required by the Competition in 
Contracting Act of 1984. 

002A 
Update the 4P Application User Guide to require 
contracting personnel to conduct additional price 
analysis on products for which the 4P tool returns 
only self-hits. 

002B 
Update the 4P Application User Guide to require 
contracting personnel to include commercial 
market pricing information presented in the 4P 
tool in price evaluations and provide justification 
when the awarded pricing exceeds the lowest 
commercial market price found. 

002C 
Update the 4P Application User Guide to require 
contracting personnel to seek, analyze, and 
document justification for product pricing that 
exceeds the market threshold. 

002D 
Update the 4P Application User Guide to require 
contracting personnel to manually research an 
appropriate sample of products for which the 4P 
tool found no market research comparisons to 
ascertain applicable market pricing information. 

003 
FAS Commissioner provide training to 
contracting personnel regarding the use of the 4P 
tool, focusing on updated 4P Application User 
Guide requirements. 

004 
FAS Commissioner develop and implement 
oversight controls to ensure contracting 
personnel are following the updated 4P 
Application User Guide. 

005 
Include commercial market pricing research on 
the 4P tool overview tab. 

006 
Include "no competitive research found" flags 
and a competitive research rate in 4P reports, 
exclusive of self-hits. 

007 
Design and implement procedures to ensure only 
accurate, current pricing is included in 4P 
reports. 




Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses in Development 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation

A210039PRR22007 
Audit of the PBS NCR's 
Metropolitan Service 
Center Reimbursable 
Work Authorizations 
9/23/2022 
001 
Direct the Reimbursable Services National 
Program to update all applicable policies and 
procedures to align with the current Reimbursable 
Work Authorizations (RWA) organizational 
structure and to clarify the roles and 
responsibilities of PBS project managers and 
OCFO budget analysts in updating the RWA 
Entry and Tracking Application (RETA) status for 
substantial completion. 

002A 
The Acting NCR Regional Commissioner should 
establish controls to ensure staff are trained on 
the PBS Reimbursable Work Authorizations 
National Policy Manual requirement to update 
RWA Entry and Tracking Application (RETA) with 
a milestone schedule or written justification. 

002B 
The Acting NCR Regional Commissioner should 
develop a program to train staff in their role in the 
revised guidance regarding updating the RWA 
Entry and Tracking Application (RETA) status for 
substantial completion. 

002C 
The Acting NCR Regional Commissioner should 
coordinate with the OCFO to ensure national 
RWA policies and goals are met for substantial 
completion dates to be entered into RWA Entry 
and Tracking Application (RETA). 



A200975Q3P22002 
FAS Cannot Provide 
Assurance that MAS 
Contract Pricing 
Results in Orders 
Achieving the Lowest 
Overall Cost 
Alternative 
9/30/2022 
001 
Cancel the Transactional Data Reporting (TDR) 
pilot in accordance with FAS Policy and 
Procedures 2016-11, Transactional Data 
Reporting - Federal Supply Schedule Program 
Implementation, Paragraph 8(G), Pilot 
Cancellation. OIG recognize that FAS rejected 
recommendations made in Report Number 
A140143/Q/6/P21002, including that FAS develop 
and implement an exit strategy for the TDR pilot 
and transition participating contractors out of the 
TDR pilot. However, OIG continues to conclude 
that the TDR pilot should be canceled. After 6 
years, the TDR pilot still has not resulted in a 
viable pricing methodology that ensures 
compliance with the Competition in Contracting 
Act of 1984 (CICA) requirement for orders to 
result in the lowest overall cost alternative to meet 
the government's needs. 



 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses in Development 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation

A200975Q3P22002 
FAS Cannot Provide 
Assurance that MAS 
Contract Pricing 
Results in Orders 
Achieving the Lowest 
Overall Cost 
Alternative 
(continued) 
9/30/2022 
002 
FAS Commissioner inform customer agencies 
that they should perform separate and 
independent price determinations because relying 
on MAS contract pricing and following the 
ordering procedures in Federal Acquisition 
Regulation (FAR) 8.405, Ordering procedures for 
Federal Supply Schedules, may not ensure 
compliance with the Competition in Contracting 
Act of 1984 (CICA) requirement that orders and 
contracts result in the lowest overall cost 
alternative. This should continue until the 
requirements and controls outlined in 
Recommendation 3 are set in place to ensure 
compliance with CICA. 

003A 
FAS Commissioner establish requirements and 
controls to ensure that FAS contracting personnel 
adequately analyze CSP information: (1) to 
negotiate pricing consistent with CICA, FAR, and 
GSA Acquisition Regulation 538.270-1, 
Evaluation of offers without access to 
transactional data; and (2) to clearly identify and 
support the determination of most favored 
customer pricing. FAS should ensure that offerors 
provide its contracting personnel with detailed 
information about the sales volumes, terms and 
conditions of pricing agreements, and any 
additional transactional discounts or pricing terms 
offered to individual commercial customers that 
receive the best pricing for the products and 
services proposed for the MAS contract. 

003B 
FAS Commissioner establish requirements and 
controls to ensure that FAS contracting personnel 
adequately analyze CSP information: (1) to 
negotiate pricing consistent with CICA, FAR, and 
GSA Acquisition Regulation 538.270-1, 
Evaluation of offers without access to 
transactional data; and (2) to clearly identify and 
support the determination of most favored 
customer pricing. FAS should establish protocols 
that require offerors to submit other than certified 
cost or pricing data to support proposed pricing 
when offerors do not have comparable sales to 
customers outside of its MAS contract. 





Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses in Development 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation 

A200975Q3P22002 
FAS Cannot Provide 
Assurance that MAS 
Contract Pricing 
Results in Orders 
Achieving the Lowest 
Overall Cost 
Alternative 
(continued) 
9/30/2022 
003C 
FAS Commissioner establish requirements and 
controls to ensure that FAS contracting personnel 
adequately analyze CSP information: (1) to 
negotiate pricing consistent with CICA, FAR, and 
GSA Acquisition Regulation 538.270-1, 
Evaluation of offers without access to 
transactional data; and (2) to clearly identify and 
support the determination of most favored 
customer pricing. FAS should cancel FAS Policy 
and Procedures 2017-02, Updated Procedures 
for Exercising the Option to Extend the Term of a 
Federal Supply Schedule Contract, and develop 
and implement policy and procedures directing 
FAS's contracting personnel to perform price 
analyses of CSP disclosures provided by the 
offeror for MAS contract option extensions. 

004 
FAS Commissioner explore new pricing 
methodologies that can ensure that its contracting 
personnel are able to leverage aggregate 
government buying power to negotiate and award 
MAS contracts that result in orders that reflect the 
lowest overall cost alternative to meet the needs 
of the government. 


A201018P4R22008 
COVID-19: PBS 
Faces Challenges in 
its Efforts to Improve 
Air Filtration in GSA-
Controlled Facilities 
9/30/2022 
001A 
PBS Commissioner for GSA-owned facilities 
conduct an accurate and complete assessment of 
HVAC systems to identify deficiencies in air 
filtration. Based upon the assessment, PBS 
should maximize central air filtration in existing 
HVAC systems without significantly reducing 
design airflow. 

001B 
PBS Commissioner for GSA-owned facilities 
review and update current and future operations 
and maintenance (O&M) contracts to ensure that 
they clearly identify the required Minimum 
Efficiency Reporting Value (MERV) air filters and 
preventive maintenance schedules. 



 


Open OIG Recommendations Not Fully Implemented (cont.) 
Audit Responses in Development 

Audit Report Number and Title of Report 
Issue Date of Report 
Recommendation Number 
Recommendation
Cited Recommendation

A201018P4R22008 
COVID-19: PBS Faces 
Challenges in its 
Efforts to Improve Air 
Filtration in GSA-
Controlled Facilities 
(continued) 
9/30/2022 
001C 
PBS Commissioner for GSA-owned facilities 
establish controls to ensure that PBS obtains and 
maintains complete preventive maintenance 
records. 

001D 
PBS Commissioner for GSA-owned facilities 
ensure contracting officer representatives conduct 
inspections of mechanical rooms and preventive 
maintenance records to ensure that air filters 
meet Minimum Efficiency Reporting Value 
(MERV) requirements. 

002A 
PBS Commissioner for GSA-leased space review 
and update current and future lease agreements 
to ensure that they clearly identify the required 
Minimum Efficiency Reporting Value (MERV) air 
filters and preventive maintenance schedules. 

002B 
PBS Commissioner for GSA-leased space ensure 
that lessors maintain and provide required 
preventive maintenance records and provide 
timely access to mechanical rooms. 

002C 
PBS Commissioner for GSA-leased space ensure 
that PBS representatives inspect mechanical 
rooms and preventive maintenance records to 
ensure that air filters meet Minimum Efficiency 
Reporting Value (MERV) requirements. 



 


Glossary of Terms 

The following definitions, based on the Inspector General Act Amendment of 1978, apply to terms used 
in this Semiannual Management Report: 

Questioned Costs Costs questioned by the OIG because of: 
• an alleged violation of a provision of a law, regulation, contract, grant, cooperative 
agreement, or other agreement or document governing the expenditure of funds; 
• a finding that, at the time of an audit, such cost is not supported by adequate 
documentation; 
• a finding that the expenditure of funds for the intended purpose is unnecessary 
or unreasonable. 

Disallowed Cost Questioned costs that GSA management in a management decision sustained or 
agreed should not be charged to the Government. 


Recommendation that Funds be Put to Better Use A recommendation by the GSA OIG that 
funds could be used more efficiently if management took action to implement and complete the 
recommendations, including: 
 
• reductions in outlays; 
• de-obligation of funds from programs or operations; 
• withdrawal of interest subsidy costs on loans or loan guarantees, insurance, or bonds; 
• costs not incurred by implementing recommended improvements related to the 
operations of the establishment, a contractor, or grantee; 
• avoidance of unnecessary expenditures noted in pre-award reviews of contract or 
grant agreements; 
• any other savings that are identified specifically. 


Management Decision The evaluation by management of the findings and recommendations 
included in an audit report and the issuance of a final decision by management and concurrence by 
the OIG concerning its response to such findings and recommendations, including planned corrective 
actions to remedy weaknesses identified in the report. 

 
Final Action The completions of all actions that GSA management concluded in its management 
decision were necessary with respect to the findings and recommendations included in the audit report. 
If GSA concluded no action was necessary, final action occurred when the management decision was 
made.


 

 

Management Actions - Questioned Costs The following are the different management actions 
used by GSA management to resolve questioned costs in an audit report. 

• Audit reports on which management decisions made during the period: Data 
pertaining to the number of audit reports on which management decisions made during the period and the associated amount of disallowed costs furnished by GSA OIG. 
• Write-offs: For the purposes of this report, write-offs represent a management decision not to recover the disallowed cost cited by the OIG report. 


Management Actions - Better Use Funds The following are the different management actions 
used by GSA management to resolve the "better use" of funds in an audit report. 

• Better Use Funds: The figure represents amounts cited as "cost avoidance" and "funds 
to be put to better use," as agreed to by GSA management and the OIG. Prior to April 1990, no 
funds were identified by the OIG specifically as "funds to be put to better use," and no 
management decisions were issued based on the consideration of "better use" of funds. 
• Budget Impact Funds: Funds identified as "budget impact" involve the obligation process. 


Audit-related savings of these funds, depending on the fund involved, may be available for 
another use. 

• No Budget Impact Funds: Funds identified as "no budget impact" are composed of estimated 
and actual amounts, and do not involve obligated monies, and therefore, cannot be construed as 
having a material effect on GSA's appropriated funds. 
• Audit reports on which management decisions made during the period: Data 
pertaining to the number of audit reports on which management decisions made during the 
period and the associated dollar amounts agreed to by management furnished by GSA OIG. 
• Value of recommendations that management concluded should not or could not be 
calculable: Management was unable to determine the award amounts and "better use funds” 
implemented since the amount is included in the overall award to the prime contractor and 
savings could not be determined.


Appendix 

Dated:  October 4, 2022

MEMORANDUM FOR EVAN FARLEY; DIRECTOR; OFFICE OF AUDIT MANAGEMENT AND ACCOUNTABILITY (BA)

Signature - L B Blanchard
FROM: LISA L. BLANCHARD; DIRECTOR; AUDIT PLANNING, POLICY, AND OPERATIONS STAFF (JAO) 

SUBJECT: Semiannual Report to the Congress on the Number of Management Decisions

This memo is intended to relate the total management decisions for the period October 1, 2021 through March 31, 2022. The totals are based on BA/JA Data Match Report, dated April 6, 2021 and JA’s AMIS database. The OIG’s management decision statistics are, as follows:

Type of Audit				Preaward
Number of Audits			17
Amount of Better Use Funds		$127,967,105		
Amount of Disallowed Costs		$371,193.00

Type of Audit				Postaward
Number of Audits			1
Amount of Better Use Funds		$0.00
Amount of Disallowed Costs		$868,640.00

Type of Audit				Internal
Number of Audits			7
Amount of Better Use Funds		$0.00
Amount of Disallowed Costs		$0.00

Audit Totals
Total Number of Audits			25
Total Amount of Better Use Funds	$127,967,105.00				
Total Amount of Disallowed Costs	$1,239,833.00

Please acknowledge your agreement of the statistics by signing below and returning to JAO as soon as possible.

Digitally signed - Evan Farley Date:2022.10.04 12:14:41-04'00' 
 

 



 

 

 


 

 


 

 

 

 

 

 

 

 

 

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