Of Interest: OIG Audits, Inspections and Reports – A Window into Contracting Operations of the US State Department

Some of us have quirky habits.  I happen to love etymology and thoroughly enjoy doing research.  As my children can well attest, I drilled into them never really to believe what they read or are told is fact; always verify the information and go to the source, whenever possible.  Even those “experts” in their fields, whether in government or out, make mistakes or may not know their subject matter as well as they think they do.

One of the things I learnt working on U.S. Government programs, whether they be contracts or grants, is that the Offices of the Inspector General (OIG) of the various government agencies put out some interesting reports that have a wealth of information.

I find these audits/reports very useful to understand:

  • what a particular agency’s strengths and weaknesses might be,
  • what the contractor/grantee can do to help the agency overcome its weaknesses,
  • what the competition’s competencies and limitations are.

Even if the audit or report pertains to a certain agency or distinct area of performance or a specific geographical place, many of the issues usually addressed do apply across the board.

For example, the latest OIG audit on contract invoicing review by the Bureau of Narcotics and International Law Enforcement Affairs (INL) actually explains the invoicing process as well as the regulations that apply to invoicing.   Program implementation benefits immensely from having program managers or contracts representatives aware of these resources.

Of course, keeping abreast of all these resources requires an enormous amount of time devoted outside of the regular work day.  However, if you are quirky, like me, it is extremely rewarding!


Human Trafficking or Trafficking in Persons (TIP)

In my experience, I have found that there tends to be a disconnect in program implementation between those who are technical experts and those who actually administer the government contract.

Government (USG) officials, companies, and NGOs have expressed concern about the risk of Human Trafficking in global supply chains, including in federal contracts. Victims originate from almost every region of the world; the top three countries of origin of federally identified victims in fiscal year (FY) 2017 were the United States, Mexico, and the Philippines.

Human Trafficking or Trafficking in Persons (TIP) is defined in the Trafficking Victims Protection Act of 2000 (TVPA). It is about people being bought and sold as chattel, involving the acquisition of a human being through the use of force, fraud, or coercion for the purpose of exploiting the individual for profit through forced labor or prostitution.  The USG efforts to combat such trafficking, also incorporated in the United Nation’s Sustainable Development Goal 8.7, are to prevent it, protect the victims, and prosecute the traffickers. A fourth “p”, involves “partnership” between the public and private sectors, with state and local organizations, and with survivors.

The annual State Department TIP Report classifies countries into tiers based on a government’s efforts to comply with the “minimum standards for the elimination of trafficking” found in TVPA.  Although the U.S. is a Tier 1 country according to the 2017 TIP Report, it is also “a source, transit, and destination country for men, women, transgender individuals, and children— both U.S. citizens and foreign nationals—subjected to sex trafficking and forced labor. Trafficking occurs in both legal and illicit industries, including in commercial sex, hospitality, sales crews, agriculture, fishing, manufacturing, janitorial services, construction, restaurants, health and elder care, salon services, fairs and carnivals, peddling and begging, and domestic service.

The National Defense Authorization Act (NDAA) allows the USG to terminate a contract if the prime contractor or subcontractor commits acts that directly support or advance trafficking in persons, such as:  confiscating an employee’s identity or immigration documents; offering employment using fraudulent or misleading pretenses; charging placement or recruitment fees; and providing housing that fails to meet the host country housing and safety standards.

Judicial reform programs might include capacity training on TIP, and it is important to understand how TIP issues can affect the federal contractor in its day-to-day business affairs.

Additional resources: