March 14, 2018

The Department of Energy’s Management of Management Operating Contractor Temporary Foreign Assignments

Due to the worldwide nature of the Department’s mission, the Department’s M&O contractor employees travel extensively to foreign countries on both short and long-term assignments. For the purpose of our audit, we focused on M&O contractor temporary foreign assignments lasting at least 6 months in duration. According to the Department’s Foreign Travel Management System, M&O contractor employees took 123 trips lasting 6 months or more at an estimated cost of just over $2 million from fiscal year 2012 through fiscal year 2015.  Department of Energy Acquisition Regulation 970.3102-05-46, Travel Costs, considers costs incurred by contractors for official travel as allowable costs and permits the contractors to have flexibility in the method used in determining these costs as long as the method used results in a reasonable charge, with some limits. Due to the amount of travel and funding involved, we initiated this audit to determine whether the Department effectively and efficiently managed M&O contractor temporary foreign assignments.

During our review, nothing came to our attention to indicate that the Department had not effectively and efficiently managed M&O contractor temporary foreign assignments. Each of the five sites that we reviewed had policies and procedures in place to manage temporary foreign assignments and generally followed those policies and procedures. When exceptions were noted to the policies at one of the five sites, the contractor had documented justification for the exceptions. Finally, although we did not identify any significant concerns with the Department’s management of M&O contractor temporary foreign assignments, we did identify an opportunity to improve consistency on the treatment of costs for foreign assignments by the Department providing greater guidance to Contracting Officers and M&O contractors on the reasonableness of costs incurred.

Because nothing came to our attention to indicate that the Department had not effectively and efficiently managed contractor temporary foreign assignments, we are not making any formal recommendations.  However, in order to provide for more consistency in the determination of cost reasonableness for temporary foreign travel, we suggest that the Director of the Office of Management, in consultation with the Department’s Program Offices, provide clarification regarding the determination of reasonableness of foreign travel costs.

Topic: Management & Administration