Audit of the Drug Enforcement Administration’s Diversion Control Support Task Orders Awarded to Ocean Bay Information and Systems Management, LLC

Require the COs and CORs to discuss and maintain an updated list of the individuals serving as government leads, including alternate points of contact.

Require CO involvement in decisions related to non-diversion activities, rather than relying solely on the government leads and CORs, to strengthen internal controls.

Create a process or control for government leads and CORs to adequately track diversion and non-diversion tasks to facilitate an accurate accounting of activities performed by the contract worker to minimize the potential risk of improperly charging costs to the DCFA.

Complete its review of the 2022 DCP ID/IQ labor qualification requirements to consider what mix of services and labor categories are needed for future task orders, and incorporate the proposed labor hour and labor category template, which should include information necessary to determine the appropriate mix of services and labor categories that are optimal to meet the DEA's operational expectations.

Complete the new labor analysis and put to better use any portion of the remaining contract value that could result in cost savings through reduced spending, avoidance of unnecessary expenditures, or reallocation of funds to higher-priority areas.

Design and implement a process or control (e.g., policies and procedures) to continuously monitor and comply with the appropriate division of labor restrictions between prime contractors and subcontractors, to include supporting documentation, such as the subcontract agreement.

Ensure that its upcoming policies and procedures give its Labor Advisor a more active role in the acquisition lifecycle to align with the goals of labor laws, related regulations, and policies as detailed in the January 2023 OMB memorandum.