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As discussed above, however, the FDICs IGCE did not include the scope and methodology, analyses (both quantitative and qualitative), conclusions, and rationale for the Agencys final procurement decision as suggested by best practices. In addition, OMB Policy Letter 11-01 established a definition for a Critical Function as "a function that is necessary to the agency being able to effectively perform and maintain control of its mission and operations. Similarly, the Board meeting minutes did not identify the procured services as Critical Functions. Appendix 6 Summary of the FDICs Corrective Actions. OMB Policy Letter 11-01 also states that [d]etermining the criticality of a function requires the exercise of informed judgment by agency officials. Program Office. Source: OIG analysis of identified best practices and the FDICs policy and procedures. Ultimately, the GAO concluded that without guidance for documenting and updating the planned Federal oversight personnel needed, and identifying oversight tasks, DHS cannot mitigate the risks associated with service contracts in need of heightened management attention. Further, GAO recommendations and other Federal agencies support that this process should be addressed within policies and procedures. According to the FDICs Selection Recommendation Report titled, Security Operations Center and Computer Security Incident Response Team Services (February 2015), the Independent Government Cost Estimate was calculated based on information acquired through historical data from the prior 3 years, as well as projects anticipated over the life of the proposed contract. As it relates to contract structure, the APM states that the contracting officer must select the type of contract and pricing arrangement that represents the most prudent and reasonable relationship with the contractor and minimizes cost and other risks to the FDIC. OMB: The source identified this item; GAO: The source identified this item; Industry Standard: The source identified this item; Select Federal Agencies: The source identified this item; OMB Guidance. Notably, the FDIC stated in its response that if the FDIC determines contract services are essential in the event of an emergency or business continuity event, the statement of work or statement of objectives must include: business continuity requirements, requirements that contractors flow emergency preparedness and continuity requirements to essential subcontracts; and requirements for contractors to have emergency plans for providing services to FDIC in the event of a disruption of normal operations, and participation in FDIC business continuity testing, training, and exercises.. The FDIC, however, provided no details as to how it plans to do so. In response to this risk, in September 2011, the Office of Management and Budget (OMB) provided guidance on managing the performance of Inherently Governmental Functions and Critical Functions in order to ensure that government action is taken as a result of informed, independent judgments made by government officials. OMBs Office of Federal Procurement Policy issued Publication of the Office of Federal Procurement Policy (OFPP) Policy Letter 1101, Performance of Inherently Governmental and Critical Functions (September 2011) (OMB Policy Letter 11-01).