Part 4. Examining Process
Chapter 46. LB&I Examination Process
Section 10. Outside Expert Program
4.46.10 Outside Expert Program
Manual Transmittal
March 15, 2024
Purpose
(1) This transmits revised IRM 4.46.10, LB&I Examination Process, Outside Expert Program.
Material Changes
(1) IRM 4.46.10.1, Program Scope and Objectives - changed Policy Owner from LB&I’s Business Solution Area to LB&I Policy under the Strategy, Policy, and Governance office in the Assistant Deputy Commissioner Compliance Integration organization.
(2) IRM 4.46.10.1, Program Scope and Objectives - added Outside Expert Program Manager as Program Owner and added Primary Stakeholders.
(3) IRM 4.46.10.1.1(4), Background - added factors to consider when requesting outside expert assistance.
(4) IRM 4.46.10.1.3, Roles and Responsibilities - expanded responsibilities of the OEP Manager, OEP Contracting Officer’s Representative, and the Issue Manager.
(5) IRM 4.46.10.1.5, Program Controls - added Program Controls.
(6) IRM 4.46.10.1.6, Terms and Acronyms - added acronyms to table.
(7) IRM 4.46.10.2, OEP Budget Committee - changed title to OEP Budget Committee from Management and Oversight of OEP and modified procedures for requesting approval for outside expert services funding.
(8) IRM 4.6.10.4, Planning for Outside Expert Assistance - further defined the role of the Case Manager and the Examination teams when planning requests for outside expert assistance.
(9) IRM 4.46.10.6, Contracting Officer’s Representative (COR) - added Specialist Referral System (SRS) as the method for requesting a COR and added reference to IRM 4.46.6, Workpapers and Reports Resources for time requirements on an exam case.
(10) IRM 4.46.10.7, Designated Point of Contact - defined the role of the Point of Contact.
(11) IRM 4.46.10.10, Requesting Outside Expert Assistance - added forms to use when requesting outside expert assistance and modified procedures to follow.
(12) IRM 4.46.10.12, Required Approvals for Funding Requests - modified approval requirements.
(13) Increased threshold for requiring various levels of approval throughout the IRM.
(14) Removed Exhibit 4.46.10-1 and incorporated it into IRM 4.46.10.1.3(17), Responsibilities and added it to IRM 4.46.10.1.6, Related Resources.
(15) Reviewed and updated website addresses, legal references, IRM references, and organization titles as necessary.
Effect on Other Documents
IRM 4.46.10 dated March 20, 2019 is superseded.
Audience
All LB&I employees
Effective Date
(03-15-2024)
Ronald H. Hodge II
Acting Assistant Deputy Commissioner Compliance Integration
Large Business and International Division
Program Scope and Objectives
(1) Purpose: This IRM provides information for LB&I’s Outside Expert Program (OEP). The guidelines and procedures described in this IRM ensure proper procurement of outside expert services at the examination and Appeals levels.
(2) Audience: These procedures apply to LB&I employees who are responsible for identifying a need for and requesting outside expert services.
(3) Policy Owner: LB&I Policy under the Strategy, Policy, and Governance (SPG) office in the Assistant Deputy Commissioner Compliance Integration (ADCCI) organization.
(4) Program Owner: The OEP is under LB&I’s Program and Business Solutions (PBS) area, in the Finance Group. The Director of PBS (Director) is responsible for executive oversight and the OEP Manager is responsible for the day-to-day operation of the program.
(5) Primary Stakeholders: LB&I senior managers, frontline managers, examiners, and program analysts.
Background
(1) The OEP reviews and approves selection of and funding for outside experts to LB&I examination teams to assist in the development of significant issues and to supplement the work of in-house personnel. OEP also provides Contracting Officer’s Representative (COR) services to examination teams.
(2) Your case may need outside expert services if it has:
Strategically managed issues
Precedent-setting issues
High dollar issues
High impact compliance issues
Significant issues where in-house expertise is limited or not available
(3) When considering the use of an outside expert, examination team members needing an expert should first discuss potential outside expert needs with team members and team management, including issue specialists and their management.
(4) Some key factors to consider when requesting outside expert assistance:
Availability of in-house specialists
Strategic initiatives and campaigns impacted
Compliance or precedence impact
Tax revenue impact
Statute and estimated completion time
Significant emerging issues
Counsel support
High potential for issue remaining unagreed and resulting in litigation
Authority
(1) Federal Acquisition Regulation (FAR) Part 7, Acquisition Plans
(2) FAR Part 11, Describing Agency Needs
Roles and Responsibilities
(1) The Director is responsible for providing executive oversight to the Outside Expert Program Budget Committee (Committee) and the OEP.
(2) The Committee provides management level oversight and guidance and acts as a liaison for the OEP.
(3) The OEP Manager and OEP Analyst are responsible for managing the daily operations of the program and either the OEP Manager or the OEP Analyst facilitate Committee meetings.
(4) A COR is an individual designated and authorized by the Contracting Officer (CO) to perform contract administration activities on their behalf within the limits of delegated authority for a specific acquisition or contract. An OEP COR must maintain their Level II or III certification. OEP CORs must be designated and authorized, in writing, by the CO to provide technical direction, monitor contract performance, and maintain an arms-length relationship with the contractor. By doing so, the OEP COR ensures the IRS pays only for the services, materials, and travel authorized and delivered under the contract.
(5) OEP contracts have a primary OEP COR and an alternate OEP COR. The CO appoints the alternate OEP COR. The alternate OEP COR performs the same function as the primary OEP COR, but only in the absence of the primary OEP COR.
(6) The OEP COR is generally responsible for:
assisting in preparation of the funding requests, including establishing Committee deadlines for approvals
preparing and ordering the acquisition requests
acting as the primary liaison between the audit team and the outside expert
coordinating with Procurement officials to facilitate contract award
coordinating the outside experts’ background investigations
assigning annual training to the outside experts
timely processing invoice payments
completing the contractor assessment in the Contractor Performance Assessment Reporting System (CPARS) at the end of the contract
(7) With respect to OEP, the issue manager is responsible for:
Engaging all exam stakeholders in the funding request process.
Ensuring the exam team requests OEP COR assistance via Specialist Referral System (SRS).
Assisting the OEP COR with the preparation of the funding request per COR request.
Securing funding approval signatures from stakeholders, by the deadline established by the OEP COR. This deadline is imposed by the Committee meetings deadlines and Procurement deadlines.
Ensuring the post-award conference is held after the background investigation and training are completed.
Providing the case closing report.
(8) The issue territory manager is responsible for reviewing the funding request and indicating approval or disapproval by signing the funding request form.
(9) The case manager should request the assignment of an OEP COR and complete administrative steps to allow the OEP COR to charge direct examination hours to the case. The case manager will also designate a point of contact (POC) for the issue if the OEP COR does not have primary responsibility for providing specialist examination support on the subject case or issue.
(10) The POC, as assigned by the examination team, is responsible for assisting in the preparation of funding requests, ensuring the outside expert receives documentation to perform contract services, and timely reviewing and approving contractor invoices by providing the OEP COR with written acceptance via email.
(11) The following specialist teams and their respective territory manager are responsible for reviewing and indicating their approvals or disapprovals of both the funding request and recommended outside expert by signing the funding request form for their respective issue:
Engineering
Economist
Transfer Pricing Practice (TPP)
Financial Products (FP)
Cross Border Activities (CBA)
Foreign Payment Practice (FPP)
Employment Tax Specialist
(12) Counsel is responsible for reviewing the performance work statement for all funding requests and providing appropriate feedback to ensure the terms would facilitate acceptable contract deliverables. For requests over $250,000, Counsel is responsible for providing a memo outlining the recommendation to procure outside expert services. For any funding request (in any amount), Counsel is also responsible for indicating approval or disapproval of both the funding request and recommended expert by either signing the funding request form or by sending an email to the OEP COR.
(13) The technical specialist is responsible for working with the audit team for funding requests over $250,000 and providing appropriate feedback on the statement of work to ensure the terms would facilitate acceptable deliverables. The technical specialist is responsible for providing a memo explaining the issue background and logical support for procuring an outside expert as well as indicating approval or disapproval of the funding request.
(14) The Director of Field Operations (DFO) is responsible for reviewing and approving funding requests of $500,000 or more that originate within their jurisdiction. When necessary, the DFO is also responsible for requesting through the OEP Manager, an ad-hoc meeting for the Committee to consider an emergency funding request if over $500,000. Only complete funding requests, including the appropriate signatures, can be submitted to the Committee for approval.
(15) The LB&I Practice Area Directors are responsible for reviewing and approving funding requests of $1,000,000 or more that originate within their jurisdiction. When necessary, the Director is also responsible for requesting through the OEP Manager, an ad-hoc meeting for the Committee to consider an emergency funding request if over $1,000,000. Only complete funding requests, including the appropriate signatures, can be submitted to the Committee for approval.
(16) The Committee is responsible for aligning outside expert funding with LB&I strategic initiatives and distributing funds in a fair and objective manner based on the merits of the requests. Committee members will follow the procedures identified in the Committee Charter, see https://irsgov.sharepoint.com/sites/LBI/SitePages/OEP2.aspx. The charter is reviewed and modified annually.
(17) All key internal stakeholders directly associated with examination of the subject should be involved in the outside expert process throughout the life of the project.
Program Management and Review
(1) Program Goals: To provide procedural guidance for LB&I examination teams engaged in procuring outside expert services and approve the necessary funding.
(2) Program Reports: At a minimum, the OEP Analyst should monitor the approved and awarded contracts and provide:
Quarterly status updates to the Committee, for prior year open contracts
Monthly status updates to the Committee for current fiscal year contracts
Program Controls
(1) All OEP CORs maintain the appropriate COR Level II or III certification and complete mandatory annual training as required by the Office of Federal Procurement Policy and the Federal Acquisition Institute. The Federal certification programs are designed to establish consistent competencies and standards for those performing acquisition-related work in civilian agencies nationwide.
(2) Any OEP COR is nominated by the OEP Manager and appointed by the CO to each contract to perform as a COR on the contract. The appointment letter identifies the OEP CORs’ duties for the duration of the contract.
(3) The OEP CORs use Invoice Processing Platform (IPP) to authorize payment of the invoices received from the OEP contractors. The requirements for receipt and acceptance of services provided by contractors are listed in IRM 1.35.3, Receipt and Acceptance Guidelines.
Note: IPP ( https://www.ipp.gov) is a secure, web-based, centralized program through which federal agencies better manage the invoicing process for goods and services, from purchase order to payment notification. The Bureau of the Fiscal Service provides this program at no cost to federal agencies and their contractors or vendors.
Terms and Acronyms
(1) The following table shows commonly used terms, acronyms, and their definitions.
Term or Acronym | Definition |
|---|---|
Case Manager | The case manager is the manager of the team who is assigned to the open examination. The case manager maintains the responsibility for the overall management of the case and must collaborate with issue managers. See IRM 4.46.1.1.3.1, General Information and Definitions, Case Manager Roles and Responsibilities for further information on the case manager. |
CO | Contracting Officer |
Committee | OEP Budget Committee |
COR | Contracting Officer’s Representative |
CPARS | Contractor Performance Assessment Reporting System |
Director | Director, Program and Business Solutions |
DFO | Director of Field Operations |
FAR | Federal Acquisition Regulation |
Issue Manager | The issue manager is primarily responsible for planning, executing, and resolving assigned issues. See IRM 4.46.1.1.3.2, General Information and Definitions, Issue Manager Roles and Responsibilities for further information on the issue manager. |
Issue Territory Manager | A mid-level manager in LB&I who supervises team managers within their territory |
JOFOC | Justification for Other than Full and Open Competition |
OEP | Outside Expert Program |
OEP COR | Contracting Officer’s Representative working in the Outside Expert Program |
Outside Experts | Individuals who are not employees of the Internal Revenue Service who are retained through contract to provide specialized assistance in return for monetary compensation. Generally, they possess a high degree of knowledge, skill, and experience in specific subject areas. IRM Exhibit 4.46.1-1 - Glossary of LB&I Terms |
P&P | Policy and Procedure |
PII | Personally Identifiable Information |
POC | Point of Contact |
PPS | Procurement for Public Sector |
SBU | Sensitive but Unclassified |
SRS | Specialist Referral System |
Related Resources
(1) IRM 1.35.24, Financial Accounting, Establishing IRS Commitments and Obligations
(2) IRM 1.35.3, Financial Accounting, Receipt and Acceptance Guidelines
(3) IRM 10.23.2, Personnel Security, Contractor Investigations
(4) Procurement Policy and Procedures Memorandum No. 32.7, The Invoice Processing Platform (IPP), https://portal.ds.irsnet.gov/sites/DCOSProcurement/PPs/pp32-7.pdf
(5) Procurement Policy and Procedures Memorandum No. 46.5, Evidentiary Documentation in Support of Receipt and Acceptance and Invoice Reviews, https://portal.ds.irsnet.gov/sites/DCOSProcurement/PPs/pp46-5.pdf
(6) See https://irsgov.sharepoint.com/sites/LBI/SitePages/Outside-Expert-Program.aspx?OR=Teams-HL=1705505341095 for general information related to the program and for the most recent version of the Committee Charter.
OEP Budget Committee
(1) The Committee is typically composed of territory and program managers (or designated senior analysts). Committee membership includes the Director and at least one representative from:
Each technical and geographic practice area
ADCCI
LB&I division (or practice area) counsel
Economist specialty
Engineer specialty
Transfer pricing area
Financial products area
(2) Conflicts of interest are considered when a committee member’s name or signature is on the Funding Request Form. In this case, the vote of the committee member does not count, and the funding request is considered approved when a majority of voting Committee members attending the meeting cast an affirmative vote.
(3) The Committee is responsible for allocating, monitoring, and controlling funding of LB&I outside expert requisitions at the examination and Appeals levels. The Committee has authority to review and recommend approval or disapproval of any request for outside expert services funding. If the funding is rejected, the exam team is allowed to present and explain the case at an ad-hoc emergency meeting or during a regular meeting. The OEP Manager or the OEP Analyst act as the Committee liaison.
(4) The Committee meets according to the charter to review funding requests.
(5) Documentation of the representative’s executive approval is required when a representative requests an ad-hoc Committee review.
Strategically Managed Issues
(1) The use of outside expert assistance is highly encouraged and is often critical on strategically managed issues and projects.
(2) In addition to providing expert reports or consulting on case specific examination issues, outside experts may also be used to provide insight to and assist the IRS in understanding issues that apply to more than one case or practice area.
Planning For Outside Expert Assistance
(1) Case Managers: should discuss the potential need for an outside expert with team members and the team management with primary responsibility for the examination issue. The issue manager is typically the team manager assigned to the examination who has day-to-day substantive responsibility for the issue under examination.
(2) Requests for outside expert services are encouraged regardless of any currently reported budget constraints.
(3) Examination teams: should strive to submit requests early in the planning phase and be aware of procurement timelines. Usually, requisition packages need to be sent to the Office of the Chief Procurement Officer (Procurement) before the end of the fiscal year’s third quarter. The annual Procurement deadlines are subject to change.
Reminder: All key internal stakeholders directly associated with examination of the subject issue must be involved in the outside expert process throughout the life of the project, from the time the decision to fund the request is made through the closeout of the contract or case.
(4) Executives at the DFO and Director level should be made aware of funding requests and support the issue under development.
Preliminary Concurrences
(1) If applicable, specialist concurrences are necessary to facilitate strategic management of resources and to maximize the benefits from the OEP within budgetary constraints.
(2) The economist team manager must obtain preliminary concurrence to request outside expert services from their direct territory manager for economist issues.
(3) The engineer team manager must obtain preliminary concurrence to request outside expert services from their direct engineer territory manager for engineer issues.
(4) The TPP team manager must obtain preliminary concurrence to request outside expert services from their direct TPP territory manager for IRC 482 or IRC 367 transfer pricing issues.
(5) Requests for actuarial services must be approved by the Pass-Through Entities practice area prior to formal submission for funding to hire outside actuary experts.
(6) The Financial Products team manager must obtain preliminary concurrence to request outside expert services from their direct territory manager.
(7) In a situation when a specialist or a specialist’ team member does not agree with a funding request or an expert, the signature is still required on the funding request form, but the specialist can select the "No" option for concurrence.
Contracting Officer’s Representative (COR)
(1) Issue Manager: Request an OEP COR using SRS as soon as key stakeholders agree on the need for outside expert assistance. The OEP Manager will contact the requester within 3 business days.
(2) The engineer team manager or economist team manager responsible for providing engineer or economist support on the issue should be the first POC when seeking COR assistance. The OEP Manager assists with COR assignments.
(3) The OEP COR is responsible for all liaison with the outside expert. Examination team members must coordinate with the OEP COR before communicating with the outside expert. Adhering to this requirement ensures understanding of the formal requirements and limitations of the contract and minimize the risk of unauthorized procurements.
(4) OEP CORs should be the first point-of-contact for guidance and assistance with all requirements and processes associated with the outside expert project. OEP CORs can provide process guidance, worksheets, forms, and templates for all required documentation associated with the requisition for outside expert services.
(5) Time spent by the exam team members in connection to the procurement of and management of a case-specific outside expert contract is case-related direct examination time. Time requirements associated with the processing and management of an outside expert requisition will vary from case to case and should follow the requirements of IRM 4.46.6 , Workpapers and Reports Resources. OEP COR records must be maintained according to the FAR 1.604, https://www.acquisition.gov/far/part-1#FAR_1_604.
(6) Once the contract is awarded, the OEP COR will work with the POC to verify the contractor’s invoice charges. The POC will approve the charges on the invoice and timely notify the OEP COR according to FAR 32.9 and Procurement Policy and Procedures (P&P) 46.5. After receiving approval from the POC, the OEP COR will promptly process contractor payments in the Service’s Procurement for Public Sector (PPS) and maintain documentation in their OEP COR administrative file.
(7) Contractors are prohibited from receiving materials containing any Sensitive but Unclassified (SBU) information or Personally Identifiable Information (PII) until they have received at least the interim staff-like access approval and have taken the mandatory training. Additionally, only after the post-award conference can contractors start working. The OEP COR is monitoring the background investigation and training processes and must notify the exam team and contractor when all the processes are completed.
Designated Point of Contact
(1) The team manager who has primary responsibility for providing specialist support on the examination of the subject issue should designate a POC if the OEP COR does not have primary responsibility for providing specialist examination support on the subject case or issue.
(2) The POC:
serves as the primary resource person to guide and assist the team and OEP COR with preparing the funding request and procurement requisition package
provides direct assistance with the management and control of the outside expert services
(3) The POC will be responsible for providing oversight to the examination team on all aspects of the OEP issue, including but not limited to assisting with the following:
Identification of the performance work statement
Identification of qualified experts
Preparation of the performance work statement
Providing oversight of the outside expert’s in-process work
Participation in meetings with the outside expert and taxpayer
Reviewing the outside expert’s deliverables, including but not limited to draft and final report(s)
Reviewing and approving contract invoices and timely notifying OEP COR according to the requirements of FAR 32.9 and Procurement P&P 46.5
(4) The case and issue managers are responsible for ensuring OEP COR and POC involvement in all aspects of preparing the funding request package and the procurement requisition package.
Area Counsel and Technical Specialist Involvement
(1) Area counsel is available to assist in determining whether an outside expert is needed and can assist with identifying an appropriate expert and with related due diligence. Area counsel and technical specialist involvement are required when the estimated cost of an outside expert is $250,000 or more. The issue manager is responsible for obtaining written recommendations from area counsel and the technical specialist. Counsel’s recommendations should include the following:
Opinion and explanation as to whether counsel supports the legal foundation for the subject issue
Opinion and explanation as to whether counsel perceives a significant potential for litigation
Indication as to whether the subject issue is docketed for trial (with any taxpayer)
Litigation history for the subject issue
(2) Counsel should clearly indicate and explain their concurrence with the need to hire the outside expert at the examination level. A similar written recommendation from the technical specialist is also required.
(3) Counsel assistance and involvement with identifying potential outside experts and preparing the statement of work is highly recommended. The issue manager should seek counsel concurrence with the selection of recommended expert(s) and statement of work.
Market Surveys
(1) At least one new potentially qualified outside expert should be contacted during the market survey process. Documentation of this contact is required. A written explanation is required if this cannot be accomplished.
(2) Due diligence is required during market research to identify potential outside experts. Examination teams should request the assistance of area counsel when performing market research. At a minimum, prior to Procurement sending out formal solicitations for outside expert services, the examination team should perform the following actions:
Check and verify all items on the outside expert’s resume, including references.
Search the internet for all material on the outside expert.
Research all cases in which the outside expert testified to determine if courts looked favorably on the outside expert.
Interview the outside expert – in addition to confirming substantive expertise in area, be sure to inquire about potential conflicts of interest and if there is anything in the outside expert’s past that could be a problem.
Review any "Past Performance" reports maintained by Procurement on the outside expert.
Secure a signed non-disclosure agreement from the outside expert if any SBU or PII information is being released for the purpose of a conflict check.
Requesting Outside Expert Assistance
(1) The examination team should coordinate with the OEP COR for current guidance and forms associated with a request for outside expert services.
(2) Requests for funding that require Committee review should be submitted to the OEP Analyst no later than fourteen (14) calendar days prior to a scheduled meeting of the Committee.
(3) All requests and associated documentation for funding for outside expert services on LB&I examinations must be submitted by secure e-mail.
(4) LB&I has specific forms that should be used to request OEP funds for initial funding requests and for additional funding requests. The funding request form is part of a funding package required to secure funding. The OEP COR assigned to the case will provide the exam team with the most recent form. The forms can also be found at OEP SharePoint: https://irsgov.sharepoint.com/sites/OutsideExpertProgramInformationalSharePoint?OR=Teams-HL=1705505471077.
(5) Generally, funding request packages for submission to the Committee should include the following:
Completed "Funding Request Form"
Required management concurrences
Requirements portion of the performance work statement
Counsel recommendation memorandum
Technical specialist recommendation
Market survey documentation
Independent government cost estimate
Justification for Other Than Full and Open Competition (JOFOC), if sole source
Signed non-disclosure agreement from recommended potential outside expert
(6) Contracts should be broken down into logical phases to better control the contracted services. The phases must be clearly identified in the contract’s statement of work. The contract-line item numbers (CLINs) in PPS are: labor (all phases), travel (all phases) and miscellaneous (all phases). All contracts must include a period of performance of 5 years. Most OEP contracts are labor hour service, non-severable.
(7) Requests must include the estimated cost for all phases of anticipated outside expert services excluding trial preparation. OEP costs are the estimated total cost of assistance at the examination level including rebuttal and Appeals assistance.
(8) The Committee must review funding requests when the total cost of all outside expert services (at both the examination and possible Appeals levels) equals or exceeds $250,000. The Committee delegated approval authority to the PBS Finance Director when the total cost is less than $250,000, except when operational budgets are constrained by a continuing resolution. The OEP Manager or OEP Analyst must discuss annually with the PBS Finance Director the requirements for the funding requests under $250,000.
(9) The Director and Committee retain ultimate authority over any recommended approvals for funding.
Requests for Additional Funding
(1) Generally, requests for additional funding on existing contracts should include the following:
Completed "Additional Funding Request Form"
Required management concurrences
Summary and status of outside expert services already received
Explanation for and justification of why additional funding is required
Independent government cost estimate and related documentation associated with the request for additional funding
Revised copy of the performance work statement, if applicable
Complete, fully documented funding request package, including the "Initial Funding Request Form" if not previously provided and any subsequent approved additional funding request forms when the total cost is $250,000 or more
(2) Requests for additional funding must be submitted to the Committee for review in these situations:
When the additional funding request is $250,000 or more
When the new total cost for the contract (including the pending funding request) is $250,000 or more
Required Approvals for Funding Requests
(1) All funding request approvals must be documented in writing on the funding request forms.
(2) For all requests, the case manager, issue manager, and issue territory manager are required to sign the funding request forms.
(3) Additional approvers of the funding request may be required depending upon the total cost of the funding request. See Funding Request Forms for required signatures.
(4) After the Committee approves a funding request, OEP Manager or OEP Analyst can sign the funding request on behalf of the Committee and return it to the OEP COR within three business days.
Timely Processing – Funded Requisition Packages
(1) The OEP COR can start the acquisition request (i.e shopping cart) at any point in the process, but can only send it for proper approval after the funding request is approved.
(2) The issue manager is responsible for ensuring the timely submission of complete, fully documented outside expert requisition packages to Procurement. Complete, fully documented requisition packages should be forwarded by the OEP COR to Procurement within thirty (30) calendar days after notification of the Committee’s approval.
(3) The OEP COR coordinates with Procurement to provide guidance associated with the preparation and submission of a fully documented procurement requisition package.
(4) Requisitions submitted to Procurement are discouraged during the fourth quarter of the fiscal year, due to Procurement’s limited resources and the processing times required to complete the award of a contract. Requisitions forwarded to Procurement in the fourth quarter are at risk for non-award. The OEP COR should coordinate with Procurement to facilitate the award of the contract prior to the end of the fiscal year. Procurement has the authority to award contracts.
Contract Management and Control
(1) The issue manager should engage all responsible team members including specialist team members and all associated team managers in the management and control of the contracted services to ensure that quality services are provided at a reasonable cost.
Post-award Conferences
(1) The issue manager is responsible for ensuring that the OEP COR conducts a post-award conference with the examination team and outside expert to explain and clarify the terms and limits of the contract and to explain roles and responsibilities and associated limits. The post-award conference must be held prior to authorizing any outside expert services under the contract. Teleconferences may be used to hold the post-award conference.
Contract Closing Reports
(1) The issue manager must provide the OEP Analyst with a contract closing report when the examination closes. The OEP COR will provide detailed instructions and assistance.
Denials of Funding Requests
(1) The OEP Manager or OEP Analyst must notify the OEP COR and case manager within three business days if an outside expert funding request is denied by the Committee. The OEP Manager or OEP Analyst will work with the case manager, issue manager and OEP COR to review reason(s) for denial and help determine alternative solutions to address the audit issue going further. After considering and addressing the recommendations of the Committee, the issue stakeholders, including the case manager, issue manager, and OEP COR can resubmit the funding request for reconsideration during a subsequent meeting.
