Controls Over Costs and Building Security Related to Outsourced Office Support Services Need to Be Improved
August 19, 2011
Reference Number: 2011-10-086
This report has cleared the Treasury Inspector General for Tax Administration disclosure review process and information determined to be restricted from public release has been redacted from this document.
Phone
Number | 202-622-6500
Email Address | TIGTACommunications@tigta.treas.gov
Web Site |
http://www.tigta.gov
HIGHLIGHTS
CONTROLS
OVER COSTS AND BUILDING SECURITY RELATED TO OUTSOURCED OFFICE SUPPORT SERVICES
NEED TO BE IMPROVED
Highlights
Final
Report Issued on August 19, 2011
Highlights of Reference Number:
2011-10-086 to the Internal Revenue Service Chief, Agency-Wide Shared
Services.
IMPACT ON TAXPAYERS
In November 2006, the Internal Revenue Service (IRS)
awarded a contract with a maximum value of approximately $90 million to a
private contractor to perform support services functions, including storage and
management, throughout IRS facilities. Overall,
TIGTA found that the IRS expends time and resources storing items it has not
clearly determined to be of future usefulness and has ineffective controls over
credentials, such as identification badges, issued to contractor
employees. As a result, the IRS may be
paying more for its support services needs than is necessary and its facilities
may be at risk for unauthorized access.
WHY TIGTA DID THE AUDIT
This
audit was initiated to determine
whether the IRS managed outsourced support services in a cost-effective manner
and minimized unauthorized access to Federal Government assets and sensitive
information associated with the program.
WHAT TIGTA FOUND
TIGTA determined that the IRS should take
additional steps to ensure support services are managed in a more cost-effective
and secure manner. Specifically, the IRS
should evaluate whether it is cost effective to continue to move into storage
rather than dispose of furniture and equipment that has not been clearly
determined to be of future usefulness.
In addition, TIGTA determined that controls should be
improved to ensure contractor employees no longer have access to IRS locations
after being separated from the contractor.
The IRS could not confirm that 116 (94 percent) of the 124
employees separated from the contractor since the initiation of the contract
returned their identification badges and building access cards as
required. As a result, the security of
IRS facilities and Federal Government assets may have been compromised.
WHAT TIGTA RECOMMENDED
TIGTA
recommended that the Director, Real Estate and Facilities Management,
Agency-Wide Shared Services, review all items currently in storage to identify
items for possible disposal; maintain documentation regarding the reason for
storage for all future items placed into warehouse storage; establish criteria
to guide future decisions regarding whether items should be placed into
storage; ensure the IRS retains flexibility to implement potential cost savings
identified as a result of inventory reviews or changes to storage policies; and
incorporate into existing procedures the required exit
procedures regarding separating contractor employees. Also, the
Director, Physical Security and Emergency Preparedness, Agency-Wide Shared
Services, should reconcile Contractor Security Lifecycle Program records
to a quarterly listing of separated employees provided by the support services
contractor.
In their response, IRS management agreed to our recommendations. Management stated that they plan to evaluate the need for continued storage of existing property; develop procedures to capture the condition, age, reason for storage, and future use of stored property; continue to routinely monitor for any changes required to the support services contract; and update existing procedures to include the process and procedures to be followed for separating contractor employees. Finally, management stated that contractors are required to report all separated contractor employee information to the Contractor Security Lifecycle Program in accordance with new security clauses. In addition, the IRS plans to have the contractor provide a quarterly list of separated contractor employees to the IRS for review.
August 19, 2011
MEMORANDUM FOR CHIEF, AGENCY-WIDE SHARED SERVICES
FROM: Michael R. Phillips /s/ Michael R. Phillips
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – Controls Over Costs and Building Security Related to Outsourced Office Support Services Need to Be Improved (Audit # 201010001)
This report presents the results of our review of outsourced support services. The overall objectives of this review were to determine whether the Internal Revenue Service (IRS) managed outsourced support services in a cost-effective manner and minimized unauthorized access to Federal Government assets and sensitive information associated with the program. This review was included in our Fiscal Year 2010 Annual Audit Plan and addresses the major management challenge of Leveraging Data to Improve Program Effectiveness and Reduce Costs.
Management’s complete response to the draft report is included as Appendix V.
Copies of this report are also being sent to
the IRS managers affected by the report recommendations. Please contact me at (202) 622-6510 if you
have questions or Nancy A. Nakamura, Assistant Inspector General for
Audit (Management Services and Exempt Organizations), at (202) 622-8500.
Appendices
Appendix
I – Detailed Objectives, Scope, and Methodology
Appendix
II – Major Contributors to This Report
Appendix
III – Report Distribution List
Appendix
IV – Outcome Measures
Appendix
V – Management’s Response to the Draft Report
Abbreviations
|
COTR |
Contracting Officer’s Technical
Representative |
|
CSLP |
Contractor Security Lifecycle Program |
|
IRS |
Internal Revenue Service |
|
REFM URS |
Real Estate and Facilities Management URS Federal Technical Services |
In November 2006, the Internal Revenue Service outsourced support
services to a private contractor. Support
services include warehousing and repairs.
In November 2006,
the Internal Revenue Service (IRS) Office of Real Estate and Facilities
Management (REFM) entered into a contract with EG&G Technical Services (a
wholly owned subsidiary of URS Corporation and later renamed URS Federal
Technical Services, Inc.) to provide support services to the IRS. Support services include the moving
and storage of equipment and furniture, inventory management of storage items,
and miscellaneous work order processing, such as property and locksmith
repairs. The contract was awarded for 5 years,
with a maximum contract value of approximately $90 million. Through April 29, 2011, URS Federal Technical
Services (hereafter referred to as URS)
had performed and received payment for services representing
approximately $79 million, with approximately $11 million of payments occurring
in Fiscal Year 2011 as of that date.
These costs relate only to payments from the IRS to URS for its performance
under the terms of the contract and do not include costs the IRS may incur
related to the support of the contract, such as oversight or rent related to
warehouse space used to store inventory.
According to the terms of the contract, URS is responsible for providing warehousing, transportation, repairs, other support services such as locksmithing, and work order processing that directly or indirectly support IRS employees located at offices throughout the 48 contiguous United States. The URS manages warehouse space at the following offices: 12 IRS campuses[1] and/or computing centers,[2] the IRS National Headquarters in Washington, D.C., and the New Carrollton Federal Building.
As part of the contract with URS, furniture and equipment, such as desks, chairs, and computer monitors, are often moved from an IRS location and placed into storage for potential future business needs. URS is responsible for moving such designated furniture and equipment within IRS office space and overseeing items in designated storage areas located within IRS space. In addition, URS agreed to provide a fully automated management information system, established as the Warehouse and Transportation Management System.[3] This system can be used to manage work order processing, including the development of databases to account for items moved from IRS locations and placed into storage.
URS employees are staffed at 10 campus locations, 2 computing centers, the IRS National Headquarters in Washington, D.C., and the New Carrollton Federal Building. After passing a required background investigation, the IRS provides URS employees daily access to IRS facilities through the issuance of identification badges and building access cards to perform the support services duties. Although URS is permitted to obtain the services of subcontractors for required services at IRS locations when necessary, our audit work did not examine the use or work activity of any subcontractors obtained by URS.
This review was performed at the Kansas City Campus in Kansas City, Missouri; the Martinsburg Computing Center in Kearneysville, West Virginia; the Brookhaven Campus in Holtsville, New York; and the Arlington, Virginia, office of the IRS Agency-Wide Shared Services, Real Estate and Facilities Management, during the period September 2010 through April 2011. We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. Detailed information on our audit objectives, scope, and methodology is presented in Appendix I. Major contributors to the report are listed in Appendix II.
We determined that the IRS should take additional
steps to ensure support services are managed in a more cost-effective and
secure manner. Specifically, the IRS
should determine if it can reduce present costs by disposing of items currently
in storage that it no longer needs. As
of September 2010, the IRS had 80,606[4] items in URS-managed storage, with 28 percent in storage 18 months or
longer with no activity. The IRS should also
evaluate whether it is cost effective to continue to move into storage rather
than dispose of furniture and equipment that it has not clearly determined to
be of use in the future. A comprehensive
evaluation of this process may enable the IRS to reduce costs and more efficiently
use its resources. This is especially
important given the current economic environment and the increased focus by the
Administration, Congress, and American taxpayers on Federal Government
accountability and efficient use of resources.
In addition, the security of IRS facilities and
Federal Government assets may have been compromised. The IRS could not confirm that 116 (94 percent)
of the 124 employees who had separated from URS since the initiation of the
contract returned their identification badges and building access cards as
required. As a result, we determined
that controls should be improved to ensure URS employees no longer have access
to IRS locations after separating from the contractor.
The Internal Revenue Service Should Take Steps to Determine if Support Services Can Be Managed in a More Cost-Effective Manner
The IRS is currently in the final option year of its original contract for support services and is now preparing to solicit bids for another support services contract. In preparation for solicitation of a new support services contract, the IRS has compiled data trending the types and frequency of work performed by the current contractor. While this trending data may provide the IRS with some beneficial management information, we believe additional steps are needed to determine how support services can be managed in a more cost-effective manner.
Specifically, the IRS has not fully considered whether the continued long-term storage of the 80,606 items in URS-managed storage is either cost beneficial or necessary to the effective delivery of its mission. While storing new or used furniture and equipment in good condition for future use may be a good use of taxpayer funds, the IRS needs to evaluate and determine whether the storage of such items is still cost effective or if the items should be disposed of, especially those items that are aged or that the IRS does not think it will use again. Hindering this evaluation is the lack of comprehensive information regarding why items were placed into storage and if, or when, it is estimated that the items will be used again. Information regarding the age and condition of items stored is also not maintained. We identified that 22,486 (28 percent)[5] of 80,606 items that reside in contractor-managed warehouse space have been in storage for 18 months or longer and have had no activity. We reviewed 90 randomly selected items placed into storage prior to October 1, 2009, and found that the IRS had not specifically identified any of these items as designated for either a renovation that was currently in process or any renovation or reconfiguration planned for the future.
The contractor provides the IRS a list of items stored in inventory that have not been used for over 10 months, and the IRS periodically distributes this list to be reviewed by REFM personnel. However, without comprehensive information regarding why these items were initially placed in storage and their age and condition, it is difficult for REFM personnel to reliably gauge the need or cost effectiveness of continuing to store these items in the warehouse. In addition, the IRS has not developed procedures to assist REFM personnel in making future decisions regarding whether items should be placed into storage or be disposed of based on an analysis of the costs and expected benefits, including the costs incurred in moving items to storage, storing the items, and returning the items to use. The Standards for Internal Control in the Federal Government requires that management identify risks and develop controls to monitor performance measures. Although the support services contract was awarded to provide cost-effective services, sufficient information is not maintained and adequate procedures have not been developed to support this objective.
Based on the
approximately 123,000 square feet used by the IRS to store inventory, we determined
that 34,194 square feet of warehouse space was devoted to the storage of the 22,486
items in storage for 18 months or longer with no further activity. If these items were not needed, the warehouse
space could have been used for other purposes.
The amount of time the 22,486 items remained unused, combined with the
lack of information on the potential future need, such as the age or condition of
the stored items or whether they were designated for a future project, raises
significant questions about the likelihood these items will be placed back into
use. The rent cost associated with these
34,194 square feet of warehouse space is approximately $862,000 annually.
Overall, we found the inventory records in two of three warehouse locations we visited to be generally accurate. However, a significant portion of stored inventory at one warehouse location we visited had been removed from the inventory control system due to construction at the facility. Specifically, the inventory items at 20 of the 30 storage locations that we sampled within this warehouse location had been relocated to an auxiliary storage room within the warehouse. After these items were moved, they were not reinventoried by URS and the new location of the items was not recorded in the inventory listing, increasing the risk that these items could be lost or misplaced. The 20 storage locations we sampled represented 97 inventory items.
Having comprehensive and reliable information regarding all items currently in warehouse storage would allow the IRS to determine if items should continue to be placed in storage in the future. In addition, this information could be used by IRS management to identify any items currently in storage that could be removed and disposed of, as appropriate. Removing unneeded items from warehouse storage could reduce costs associated with contractor management of stored items. Further, it could enable the IRS to potentially use for other purposes space currently devoted to storing unneeded items.
In addition, since the IRS is considering a new contract for support services, the IRS needs to ensure that the next contract will allow the IRS to make cost-effective decisions about the level of support services needed. For example, the IRS may not complete our recommended action to assess the level of support services needed before the next contract is awarded. If the IRS locks into contract terms at a higher level of service than needed, the IRS will be wasting taxpayer funds paying for unneeded services. The new contract should allow for reduced costs if the IRS reduces its level of support services.
Recommendations
The Director, REFM,
Agency-Wide Shared Services, should:
Recommendation
1:
Perform a nationwide, one-time
review of all items currently in warehouse storage to identify any items for
possible disposal and ensure all items are recorded on the inventory system.
Management’s Response: IRS management agreed with our recommendation and will develop an action plan to evaluate the need for continued storage of existing property. For items that do not require continued storage, REFM personnel will begin the disposal process.
Recommendation 2: Develop procedures requiring responsible REFM personnel at
each warehouse storage site to maintain documentation regarding the condition,
age, and reason for storage, including expectations for future use, for all
future items placed into warehouse storage.
Management’s Response: IRS management agreed
with our recommendation and plans to develop, implement, and maintain
procedures that will capture the condition, age, and reason for storage,
including expectations for future use for all items placed into warehouse
storage. In addition, to ensure stored
furniture will be better tracked and made available for reuse, the IRS plans to
implement a new process for palletizing complete workstations.
Recommendation 3: Develop procedures to establish criteria to guide future decisions regarding whether items should be placed into storage or be disposed of. The IRS should consider the costs and benefits of placing items in storage, including the costs incurred in moving items to storage, storing them, and returning the items to use as compared to the cost of replacing the items.
Management’s
Response: IRS management agreed with our recommendation and stated
that the IRS is developing procedures to address the need for storage, the
length of storage, and the future use of stored property. These procedures will consider current and
future budget constraints, the sustainability initiative to increase the reuse
and recycling of furniture, costs to store versus to purchase new furniture, and
transportation costs.
Recommendation 4: Ensure that the IRS retains flexibility when negotiating the terms of the next support services contract to implement potential cost savings identified as a result of inventory reviews or changes to storage criteria or policies to ensure it does not pay for unneeded support services.
Management’s Response: IRS management agreed with our recommendation and plans to continue to routinely monitor for any changes required to the support services contract. All pertinent information regarding required changes will be presented to the Office of Procurement for necessary processing and contract modifications.
Controls Over Contractor Employee Access to Federal Government Assets and Facilities Are Ineffective to Guard Against Unauthorized Access
Overall, we found that controls over contractor employee access to Federal Government assets and sensitive information associated with the program are ineffective to guard against potential unauthorized access. We determined that 124 URS employees had separated from the contractor since the initiation of the contract with the IRS. However, the IRS could not confirm that 116 (94 percent) of the 124 separated employees returned their badges and building access cards as required. The IRS informed us that 37 (32 percent) of the 116 separated contractor employees did not complete required background checks and were not issued badges, and 22 (19 percent) of the 116 separated contractor employees performed work in locations that required the badges to be returned to building security personnel prior to the contractor employee leaving the building. However, the nonissuance or final disposition of badges returned by certain employees could not be fully substantiated due to the lack of reliable records. As a result, these private contractor employees potentially still have access to IRS campus locations and field offices. As these IRS facilities perform duties such as processing taxpayer returns and providing customer service to taxpayers, unauthorized persons may have access to sensitive information and IRS personnel performing tax-related duties. We determined that these 116 employees potentially have unauthorized access to 12 IRS campuses and computing centers, as well as to the IRS National Headquarters in Washington, D.C., and the New Carrollton Federal Building. These locations contain 39,659 IRS employees who are placed at risk from the potential presence of unauthorized persons.
At the above locations, contractor employees receive security clearance if they receive required background checks. We selected a sample of 61 contractor employees who performed work and had been granted access to IRS facilities between November 2006 and August 2010 and determined that the IRS properly ensured that all 61 employees received security clearances following required background checks. These contractor employees are granted unescorted access to IRS facilities and receive identification badges and building access cards where required. Contractor employees separating from work on the contract must return to the IRS any IRS facility access media, including identification badges and building access cards.
The local Contracting Officer’s Technical Representative (COTR)[6] is tasked with completing the Separating Contractor Checklist, which documents the return of any facility access media issued to the contractor employee and the dates those actions took place. The checklist and the returned facility access media should be forwarded to the Contractor Security Lifecycle Program (CSLP) Office within the office of the Agency-Wide Shared Services. Further, the CSLP Office is responsible for processing and coordinating activities provided in the Separating Contractor Checklist and serves as the primary point of contact and subject matter expert on the contractor separating process.
Although
procedures for local COTRs were developed, the IRS informed us that not all local
COTRs were aware of their responsibilities relating to the separation of
contractor employees. As a result, local
COTRs may not be fully aware of the critical importance of 1) securing access
materials from contractor employees upon separation, 2) documenting receipt of
these materials on the Separating Contractor Checklist, and 3) promptly
returning unneeded facility access media to the CSLP Office. Without
a reliable methodology for ensuring that separated employees return their
badges and building access cards, the risk of unauthorized access to IRS
facilities is significantly increased.
During our field
work, the IRS issued a Policy and Procedures Memorandum in March 2011 revising
the roles and responsibilities of IRS personnel in regard to contractor
employee security issues. The memorandum
stated that the COTRs are responsible for completing the Separating Contractor
Checklist and submitting it to the CSLP Office, coordinating with the CSLP Office
on separation processes, and obtaining documentation from the contractor that
access to IRS-owned or controlled facilities and IRS information systems
(regardless of location) has been properly and fully terminated. The memorandum also now requires contractors
to directly inform the COTR and the CSLP Office within 1 business day of the
separation of an employee. The IRS has
incorporated the new requirements into the support services contract. While the new procedures address the
weaknesses we identified in this audit, the IRS must ensure that the new
procedures are incorporated in COTR procedures and that responsible personnel
are trained on the new requirements. In
addition, a list of separated contractor employees provided by the contractor
to the IRS would enhance the IRS’s ability to identify separated contractor
employees who were not reported as required through submission of the
Separating Contractor Checklist.
Our audit testing focused on contractor employees only and did not include a determination of whether any actual unauthorized access was attempted. We referred our findings regarding the 116 separated contractor employees to the Treasury Inspector General for Tax Administration’s Office of Investigations for further inquiry and development.
Recommendations
The Director, REFM, Agency-Wide Shared Services, should:
Recommendation
5: Ensure
the required exit procedures that local COTRs should
follow for separating contractor employees, including the proper completion of
the Separating Contractor Checklist, are incorporated into existing procedures
developed specifically for local COTRs performing work under the support
services contract. The Director should
also ensure training on the required procedures is provided to the COTRs.
Management’s Response: IRS management agreed
with our recommendation and plans to update the existing Sub-COTR Desk Guide to
include the process and procedures to be followed for separating contractor
employees. The desk guide will include
the requirement to complete the Separating Contractor Checklist, and
appropriate training will be provided by the REFM Office.
The Director,
Physical Security and Emergency Preparedness, Agency-Wide Shared Services, in
coordination with the Director REFM, Agency-Wide Shared Services, should:
Recommendation 6:
Reconcile the CSLP Office records to a quarterly list of separated
contractor employees (by separation date) provided by the support services
contractor. The contractor should first
forward the list to the REFM Office, which will then forward the list to the CSLP
Office. This requirement should be
included in any future support services contract.
Management’s Response: IRS management agreed with our recommendation and stated that the current contractor and any follow-on contractors are required to report all separated contract employee information to the CSLP Office in accordance with the new security clauses. In addition, the contractor shall provide a quarterly list of separated contractor employees to the REFM Office for review. Once the REFM Office completes its review, the list will be provided to the CSLP Office for further processing.
Appendix I
Detailed Objectives, Scope, and Methodology
Our overall objectives were to determine whether the IRS managed outsourced support services in a cost-effective manner and minimized unauthorized access to Federal Government assets and sensitive information associated with the program. To accomplish our objectives, we:
I. Determined whether the IRS had established effective controls to minimize the costs associated with outsourced office support services.
A. Identified the type of information available to IRS management to monitor program costs.
B. Determined whether the IRS is making cost-effective decisions regarding the use of contractor-managed storage.
1. Selected three IRS warehouse facilities managed by the contractor which were used for maintaining IRS assets such as equipment and furniture. We judgmentally selected these 3 sites from a total population of 13 sites to ensure that the sites in our sample contained varied attributes unique to each IRS warehouse facility.
a) Selected a random sample of 30 storage locations within each of the 3 warehouse facilities selected and physically verified that items in each location were present and should be stored based on the terms of the contract. We used a random sample to ensure each storage location had an equal chance of being selected. The storage location population size was 999 locations in the Kansas City Campus, 674 locations in the Martinsburg Computing Center, and 171 locations in the Brookhaven Campus.
b) Reviewed a random sample of 30 storage locations within each of the 3 warehouse facilities that contained items originally placed into storage prior to October 1, 2009, to determine why the items were placed in storage rather than disposed of. We used a random sample to ensure each storage location had an equal chance of being selected. The storage location population size was 768 locations in the Kansas City Campus, 670 locations in the Martinsburg Computing Center, and 81 locations in the Brookhaven Campus.
2. Determined whether the IRS performed routine periodic reviews to verify the accuracy of items claimed to be stored by the contractor.
C. Determined the reliability of computer processed data by comparing the database lists of overall inventory and aged inventory to identify potential missing records. We determined the data was sufficiently reliable to support our tests.
II. Evaluated the IRS’s process used to assess whether the outsourcing of support services is cost beneficial by reviewing whether the IRS is gathering sufficient management information to provide the basis for future decisions on outsourced support services contracts.
III. Assessed the process used to minimize unauthorized access to Government assets and sensitive information by contractor employees.
A. Assessed whether contractor personnel with access to IRS data and assets have undergone required security clearances.
1. Selected a random sample of 50 contractor personnel with current (not terminated or otherwise separated per IRS records) access to IRS facilities and evaluated whether the sample personnel had a successfully completed background investigation. We used a random sample to ensure each contractor employee had an equal chance of being selected. The population of our sample was 106 employees.
2. Identified contractor employees (11 total contactor personnel) who had current access to the facilities selected in Step I.B.1, but were not selected in the sample of 50 contractor personnel in Step III.A.1, and determined whether all employees had a successfully completed background investigation.
B. Evaluated the process used to restrict access to only authorized contractor employees.
Internal controls
methodology
Internal controls relate to management’s
plans, methods, and procedures used to meet their mission, goals, and
objectives. Internal controls include
the processes and procedures for planning, organizing, directing, and
controlling program operations. They
include the systems for measuring, reporting, and monitoring program
performance. We determined the following
internal controls were relevant to our audit objectives: the IRS’s policies and procedures for
managing its support services contract and preventing unauthorized access to
IRS facilities. We evaluated these controls by interviewing management,
reviewing a sample of items stored at selected sites, and reviewing applicable
documentation.
Appendix II
Major Contributors to This Report
Nancy A. Nakamura, Assistant
Inspector General for Audit (Management Services and Exempt Organizations)
Jeffrey M. Jones, Director
Anthony J. Choma, Audit Manager
Seth A. Siegel, Lead Auditor
James S. Mills, Jr., Senior Auditor
Joseph P. Smith, Senior Auditor
Appendix III
Commissioner C
Office of the Commissioner – Attn: Chief of Staff C
Deputy Commissioner for Operations Support OS
Director, Physical Security and
Emergency Preparedness
OS:A:PSEP
Director, Procurement OS:A:P
Director, Real Estate and
Facilities Management
OS:A:RE
Chief Counsel CC
National Taxpayer Advocate TA
Director, Office of Legislative Affairs CL:LA
Director, Office of Program Evaluation and
Risk Analysis RAS:O
Office of Internal Control OS:CFO:CPIC:IC
Audit Liaison: Chief, Agency-Wide Shared Services OS:A
Appendix IV
This appendix presents detailed information on the measurable impact that our recommended corrective actions will have on tax administration. These benefits will be incorporated into our Semiannual Report to Congress.
Type and Value of Outcome Measure:
· Inefficient Use of Resources – Potential; $861,689 (see page 3).
Methodology Used to Measure the Reported Benefit:
We identified 22,486 (28 percent)[7] of 80,606 items
that reside in contractor-managed warehouse space have been in the warehouse
for at least 18 months and have not had any activity since they were placed in
inventory. The amount of time these
items have remained unused, combined with the lack of information on the
potential future need, such as the age or condition of the stored item or whether
they were designated for a future project, raises significant questions about
the likelihood the items will be placed back into use. Based on the
approximately 123,000 square feet used by the IRS to store inventory, we determined
34,194 square feet of warehouse space was devoted to the storage of the 22,486
items. The rent cost associated with
these 34,194 square feet of warehouse space is approximately $862,000
annually.[8]
Type and Value of Outcome Measure:
· Reliability of Information – Potential; 97 inventory items removed from contractor management and inventory control system (see page 3).
Methodology Used to Measure the Reported Benefit:
During a site visitation to one contractor-managed IRS warehouse facility, we identified that a significant portion of stored inventory had been removed from the inventory control system due to construction at the facility. Specifically, the inventory items at 20 of the 30 storage locations within the 1 warehouse location we sampled had been relocated to an auxiliary storage room within the warehouse. After these items were moved, they were not reinventoried by URS and the new location of the items was not recorded in the inventory list, increasing the risk that these items could be lost or misplaced. The 20 storage locations we sampled represented 97 inventory items.
Type and Value of Outcome Measure:
· Protection of Resources – Potential; 14 facilities, including 12 IRS campuses and/or computing centers, the IRS National Headquarters in Washington, D.C., and the New Carrollton Federal Building which are potentially at risk for unauthorized access; and 39,659 total IRS employees working and potentially affected in those 14 facilities (see page 6).
Methodology Used to Measure the Reported Benefit:
Using lists provided to us by the IRS, we identified 124 contractor employees that either
separated from contractor employment or could not be definitively identified as
currently employed based on the information provided in the lists. However, these lists did not contain
sufficient information and the IRS could not provide corroborating
documentation to confirm that 116 (94 percent) of the 124 separated contractor
employees properly returned facility access credentials, such as identification
badges and building access cards, upon their separation from employment. As a result, these private contractor employees potentially still have
access to IRS campus locations and field offices. URS maintains employees at 14 IRS facilities
and, using the IRS’s Graphic
Database Interface system, we identified 39,659 IRS employees who work at those
14 locations.
Appendix V
Management’s Response to the Draft Report
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
CHIEF
AGENCY-WIDE
SHARED
SERVICES
July 22, 2011
MEMORANDUM
FOR MICHAEL R. PHILLIPS
DEPUTY INSPECTOR GENERAL FOR AUDIT
FROM: David A. Grant /s/ David A. Grant
Chief, Agency-Shared Services
SUBJECT: TIGTA Draft Audit Report
#201010001 - "Controls Over Costs and Building
Security Related to Outsourced Office Support Services"
Thank you for
the opportunity to comment on the subject report. We agree with the recommendations
and our corrective actions are listed in the attachment.
I take the
findings very seriously and we will ensure that support services are managed in
a more cost effective and secure manner. We have already taken steps to
identify appropriate corrective actions.
In addition,
I recognize the potential for further improvement regarding our controls to prevent
separated contract employee access to IRS locations. We are working with the Director,
Physical Security and Emergency Preparedness (PSEP) and members of his staff to
implement corrective actions and identify other relevant practices that should
be adopted within Real Estate and Facilities Management (REFM).
Thank you for
your guidance in this effort. If you have any questions, please contact me or
J. Stuart Burns, Director, Real Estate and Facilities Management, at (202)
435-6300. For matters concerning evaluation follow-up, please contact Larry
Pugh, Office of Strategy and Finance, Agency-Wide Shared Services, at (202)
622-4541.
Attachment
Attachment
RECOMMENDATION #1: Perform a nationwide, one-time review of
all items currently in warehouse storage to identify any items for possible
disposal and ensure all items are recorded on the inventory system.
CORRECTIVE ACTION: We agree with this recommendation. An action plan will be developed
requiring each territory to evaluate the need for continued storage of existing
property. For those items that do not require continued storage, Real Estate
and Facilities Management personnel will begin the disposal process.
IMPLEMENTATION DATES:
RESPONSIBLE OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE ACTION MONITORING PLAN: REFM will enter accepted corrective actions
into the Joint Audit Management Enterprise System (JAMES). These corrective actions
are monitored on a monthly basis until completion.
RECOMMENDATION #2: Develop procedures requiring responsible
Real Estate and Facilities Management personnel at each warehouse storage site
to maintain documentation regarding the condition, age, and reason for storage,
including expectations for future use, for all future items placed into
warehouse storage.
CORRECTIVE ACTION: We agree with this recommendation. Real
Estate and Facilities Management will develop, implement, and maintain standard
operating procedures (SOPs) that will capture the condition, age, and reason
for storage, including expectations for future use, for all items placed into
warehouse storage. In addition, to ensure stored furniture will be better
tracked and made available for re-use, we will implement a new process for
palletizing complete workstations.
IMPLEMENTATION DATE: December 31, 2011
RESPONSIBLE OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE ACTION MONITORING PLAN: REFM will enter accepted corrective actions
into the Joint Audit Management Enterprise System (JAMES). These corrective actions
are monitored on a monthly basis until completion.
RECOMMENDATION #3: Develop procedures to establish criteria to
guide future decisions regarding whether items should be placed into storage or
be disposed of. The IRS should consider the costs and benefits of placing items
in storage, including the costs incurred in moving items to storage, storing
them, and returning the items to use as compared to the cost of replacing the
items.
CORRECTIVE ACTION: We agree with this recommendation. There is
an initiative underway within Real Estate and Facilities Management to develop
standard operating procedures that will address the need for storage, the
length of storage, and the future use of stored property. These procedures will
consider current and future budget constraints, the sustainability initiative
to increase the re-use and recycling of furniture, costs to store versus to
purchase new furniture, and transportation costs.
IMPLEMENTATION DATE: December 31, 2011 - Develop and implement
standard operating procedures
RESPONSIBLE OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE ACTION MONITORING PLAN: REFM will enter accepted corrective actions
into the Joint Audit Management Enterprise System (JAMES). These corrective actions
are monitored on a monthly basis until completion.
RECOMMENDATION #4: Ensure that the IRS retains flexibility
when negotiating the terms of the next support services contract. This will
afford an opportunity to implement potential cost savings identified as a
result of inventory reviews or changes to storage criteria or policies to
ensure we do not pay for unneeded support services.
CORRECTIVE ACTION: We agree with this recommendation. The
National COTR team will continue to routinely monitor for any changes required
to the support services contract. All pertinent information regarding required
changes will be presented to the office of Procurement for necessary processing
and contract modifications.
IMPLEMENTATION DATE: June 30, 2011
RESPONSIBLE OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE ACTION MONITORING PLAN: REFM will enter accepted corrective actions
into the Joint Audit Management Enterprise System (JAMES). These corrective actions
are monitored on a monthly basis until completion.
RECOMMENDATION #5: Ensure the required exit procedures that
local COTRs should follow for separating contractor employees, including the
proper completion of the Separating Contractor Checklist, are incorporated into
existing procedures developed specifically for local COTRs performing work under the
support services contract. The Director should also ensure training on the
required procedures is provided to the COTRs.
CORRECTIVE ACTION: We agree with this recommendation. Real
Estate and Facilities Management will update the existing Sub-COTR Desk Guide
to include the process and procedures that shall be followed for separating
contractor employees. The desk guide will include the requirement to complete
the Separating Contractor Checklist. Appropriate training will be provided by
Real Estate and Facilities Management.
IMPLEMENTATION DATES:
RESPONSIBLE OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE ACTION MONITORING PLAN: REFM will enter accepted corrective actions
into the Joint Audit Management Enterprise System (JAMES). These corrective actions
are monitored on a monthly basis until completion.
RECOMMENDATION #6: Reconcile the CSLP Office records to a
quarterly list of separated contractor employees (by separation date) provided
by the support services contractor. The contractor should first forward the
list to the Real Estate and Facilities Management Office, which will then
forward the list to the CSLP Office. This requirement should be included in any
future support services contract.
CORRECTIVE ACTION: We agree with this recommendation. The
current contractor and any follow-on contractors are required to report all
separated contract employee information to CSLP in accordance with the new
security clauses outlined in Policy and Procedures 39.1 (c), specifically
clause IR1052.204.9006, entitled "Notification of Change in Contractor
Employee Employment Status, Assignment or Standing (August 2010)."
The
Contractor shall provide a quarterly list of separated contractor employees to
Real Estate and Facilities Management for review. Once Real Estate and
Facilities Management completes its review, the list will be provided to CLSP
for further processing. The quarterly list will provide the following
information: Name of Contractor Employee; Date of Separation; Date Separating
Contractor Checklist (SCC) was completed; and Date SCC was submitted to
Physical Security and Emergency Preparedness (PSEP).
IMPLEMENTATION
DATE: February 22, 2011 (COMPLETED) - Contract
Modification #86 to Policy and Procedures 39.1 (c) now requires the contractor
to provide
a quarterly listing of separated
contract employee, commencing the end of the 4th quarter 2011.
RESPONSIBLE
OFFICIAL: Director, Real Estate and Facilities
Management, Agency-Wide Shared Services
CORRECTIVE
ACTION MONITORING PLAN:
REFM will enter accepted
corrective actions into the Joint Audit Management Enterprise System (JAMES).
These corrective actions are monitored on a monthly basis until completion.
[1] The data processing arm of the IRS. The campuses process paper and electronic submissions, correct errors, and forward data to the computing centers for analysis and posting to taxpayer accounts.
[2] IRS computing centers support tax processing and information management through a data processing and telecommunications infrastructure.
[3] The Warehouse and Transportation Management
System is an automated inventory and information system that manages
warehousing, transportation, repairs, and other logistic services. This system records and tracks all the work
performed by URS, maintains a complete inventory of all products stored, and
generates work tickets for URS based on work requests from the IRS.
[4] There were a total of 176,075 items in warehouse storage, including boxes and paper. Boxes and paper constituted 95,469 items as of September 2010. We excluded boxes and paper from our inventory count as those items are not significant in terms of space used.
[5] The IRS provided to us the list of 80,606 items maintained in storage as of September 14, 2010, and the list of items in storage 10 or more months with no activity as of September 1, 2010. The slight difference in the timing of the two lists was not deemed to be material.
[6]
The primary role of
the COTR is to provide technical direction, monitor contract performance, and
maintain an arm’s-length relationship with the contractor, ensuring that the
Federal Government pays only for the services, materials, and travel authorized
and delivered under the contract.
[7] The exact figure for calculation purposes is 0.278.
[8] Using the IRS’s Graphic Database Interface system, we calculated the average rent cost of the 14 IRS facilities used to store inventory at $25.20 per square foot per year. As a result, the value of the resources which could be available to the IRS for other purposes is $861,688.80 ($25.20 multiplied by the 34,194 square feet).