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DHS Needs to Improve Implementation of OCFO Policy Over Reimbursable Work Agreements

Executive Summary

In fiscal year 2014, DHS spent a total of $12.5 billion using interagency agreements. Past Office of Inspector General audit reports found that a component used Intra/Interagency Reimbursable Work Agreements (RWA) to bypass key internal controls rather than properly implement Interagency Acquisitions. We conducted a department-wide audit to determine whether DHS’s use of RWAs is in compliance with statutory, regulatory, departmental, and component requirements. Components are not issuing RWAs in compliance with the Department’s policy. Specifically, 100 percent of the 43 RWAs we tested—totaling approximately $88 million—had not been reviewed by a Certified Acquisition Official (CAO). In January 2015, DHS issued a policy requiring components to have a CAO review RWAs to ensure they are being issued properly prior to obligating funds. The CAO plays a critical role in ensuring high-risk transactions receive proper oversight. However, 70 percent of the RWAs we tested did not include enough information for a CAO to make an informed decision. DHS did not ensure components updated their policies and procedures to reflect the new requirements. Without a CAO review, components may continue to improperly issue RWAs, circumventing acquisition controls.

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