Job Order Contract Internal Control Checklist

The potential for fraud, waste or abuse exists for Job Order Contracting as it does for any other construction delivery method.   A review of audits performed on Job Order Contract is ample evidence of how lack of proper JOC Program set-up, internal controls, or lack of performance for owners or contractors has created non trivial issues.

It is important and necessary to be alert to the potential for fraud, waste, and abuse, and to take reasonable, prudent, efficient actions and implement appropriate safeguards.

  • Personnel to be assigned to work with JOC should be carefully screened to ensure only competent individuals with a high degree of integrity are assigned.
  • Managers at all appropriate levels should be required to ensure that
    • JOC personnel are properly trained to do their jobs.
    • JOC personnel are familiar with and understand the terms of the contract they are executing.
    • that the procedures established are followed for processing JOC actions from start of job to finish of contract administration.
    • all JOC personnel read and adhere to standard for ethical conduct.
    • JOC personnel seek assistance and guidance before proceeding on unclear or borderline issues.
    • Meaningful quarterly reviews of JOC operations will be made by technical/engineering/ facility management staff and contracting/purchasing/procurement staff.
    • All personnel concerned will ensure work scopes, government estimates, contractor’s proposals, awarded task orders, and contractor invoices are logically progressive, consistent and clear.
    • Project scoping and project quality control/acceptance activities will be kept separate. Individuals involved with project scoping and development as well as proposal negotiations with the contractor will not be the same individual responsible for monitoring quality assurance. Although project engineers may be required during the construction phase to clarify scope of work or recommend modifications for changes or unforeseen conditions, the responsibility for recommending acceptance of completed work will remain with separate quality assurance personnel. This principle of separation should also allow for effective coordination between project engineers and quality assurance persons so that problems occurring during the construction phase do not cause contractor delays and potential claims to the government.
  • The head of the team or division with responsibility for the Job Order Contract should be required to…
  • make certain contract administration documentation activities are kept current, complete and correct.
  • conduct periodic sessions among JOC personnel to discuss their work activities, procedures and problems.
  • Complete at least annually, a JOC internal control checklist and/or audit.
  • Assure all aspects of the JOC SOP (Standard Operating Procedure) properly identify authorities, limitations, and responsibilities of all technical and contracting/purchasing  personnel involved in the JOC contract, and that processes are being followed.
  • Review the JOC unit price book to assure it is sufficient to meet JOC requirements and updated per changed to meet the specific needs on an annual basis.
  • Require all JOC participants (internal and contractor) receive training and orientation regarding policy and procedures for operation of the JOC contract which specifically addresses their authorities, limitations and responsibilities.
  • Assure  statements of work for proposed task orders under a JOC contract contain sufficient detail to assure that the owner can properly develop an estimate and that the contractor can properly prepare responsive and cost-effective proposals with a minimum of non-prepriced work.
  • Review any  significant differences between owner estimates and contractor proposals and determine reasonableness of bids and/or accuracy of estimates.

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