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Management Advisory Report: Seed Global Health Services

Report Information

Date Issued
Report Number
IG-19-01-SR
Report Type
Review
Component
Agency-wide
Description
Our review found that the Peace Corps did not fully comply with applicable Federal requirements relating to cooperative agreements and lacked internal controls in making the award to Seed Global Health Services. Specifically, the Peace Corps did not have sufficient documentation to justify awarding the cooperative agreement without competition. This made the Peace Corps vulnerable to the perception of favoritism by obligating a total of approximately $7.5 million in Department of State funding to Seed Global Health Services. We found several weaknesses caused by insufficient controls: the lack of segregation of duties for a senior agency official, the lack of key policies governing cooperative agreements, poor file management and failure to obtain the necessary anti-lobbying certifications from Seed Global Health Services. This report makes five recommendations to help enhance controls over cooperative agreements.
Participating OIG
Peace Corps OIG
Agency Wide
Yes (agency-wide)
View report on Oversight.gov

Recommendations

Disclaimer: Open/Closed recommendations are updated semiannually.

We recommend that the Director of the Peace Corps require the Chief Acquisition Officer to implement procedures and practices that ensure proper segregation of duties to avoid potential conflicts and appearances of favoritism in the cooperative agreement award process.

We recommend that the Director of the Peace Corps establish comprehensive agency policy and procedures on cooperative agreements with non-governmental entities. At minimum, such policy should address the need for competition, circumstances where competition is not required, justifications for noncompetitive awards, and appropriate limitations on cooperative agreement extensions.

We recommend that the Director of the Peace Corps require the Chief Acquisition Officer to implement a record management system for cooperative agreements, to include maintaining specific written documentation to justify all future non-competitive agreements in the agreement file that will assist other staff in substantiating decisions made by former staff.

We recommend that the Director of the Peace Corps require the Chief Acquisition Officer to submit to GSA’s Catalog of Federal Domestic Assistance complete and accurate information regarding all grants and cooperative agreements with the Peace Corps.

We recommend that the Director of the Peace Corps require the Chief Acquisition Officer to review relevant Peace Corps contracts, grants, and agreements to ascertain that each file contains the proper anti-lobbying certification, in compliance with applicable laws and regulations and report to OIG the failure of any entity to submit required certifications.