Review of Contracting Issues at Los Alamos National Laboratory 4 Summary, -- . .. - were in the form ofe mail updates sent from Ms. Heather Wiison. She provided three mails that exemplified her comments. A533 We asked she reviewed and approved the invoices for payment. She replied that she did review and approve the invoices. She stated that she determined that Ms. Wilson was Completing the items listed on the task orders, although there were many items that were err-going. We stated that there were many months in which the task orders were identical. She replied that some task orders did remain the same and some did change. However-stated that she would re-visit the task orders everv month and receive assurances that Ms. Wilson was fulfilling the tasks. She stated that she informally verified the invoices provided . CJ . . We confirmed that as also as an for the CPA Heather Wilson. We asked why he was assigned to the CPA. 6) replied that management felt that a High Level Mane-ar?s input was needed. We asked $13563 (bit?) 'i oordinated that tasks and review of invoices with? She replied that she did coordinate with 031% ?lm I She stated that she worked closely with big? ilslon and through conversations, eumails and calendar requests. We requested from 6] a few examples of e?mail traffic indicating coordination, tasking and verification tasks were completed. I Conclusion: Notes: Results A.9.PRG - SNL Purpose: (Edit?) (bl Procedure Step: ETJECJ First Source: Type: Assigned To: 091? Scope: Prepared By: Sam 6f6f2014 Reviewed By: {None} Methodology: Review of Contracting Issues at Los Alamos National Laboratory Summary I fie-tail PROPERTIES: Details: Location: Frequency: Record of Work Done: (131(6) @0ch . . Category 4: On October 25 2012 Ins ectors analE Iinterviewed . User Category: lat Sandia National Laboratory. Iwas accompanied by Categorys The interview took place in the Ivan Rose room, Sandia National Laboratory. The purpose ofthe interview Cotegory? was to discuss a consulting subcontract awarded to Ms. Heather Wilson by Sandia National Laboratory. The interview was basically as follows: SCORECARD: Rating: We asked_howlon:_- she had been with Government Relations She replied that she has been In Sample Size: . her current Position sinc - hat?tated that she was an JSJ JCJ Iwith organization 2009. She stated thatlEbJE?J JECJ Iwas her- (C) at that time. 5 II - - We confirmed wit the SJ on PD 8809?4. She stated that she was requested by managemen to construct a consultant agreement. stated that it she worked forlEle?J office at the time. We asked what discussions too a ace an with whom that resulted in a purchase requisition (PR) for a subcontractor with this that she was told who the contract was going to be with. We asked who comprised the SOW for the consultant. She replied that she drafted EEJEJJECJ Iwith input Istated that she anticipated thatIlel?J was going to work closely with Heather Wilson- She said that the Statement of Work was broad bacause Heather Wilson was to provide advisory services that were not limited to officemstated that they anticipated more than one end user. We asked it they identified all the end?users.? stated that all end-users for PD 8809?4 were identi?ed and listed with end?users for the CPA that was issued three months later. We asked who directed the contractor on the contract. eplied that she be contractor. She stated that in the beginning, she initiated the work. However 6J JJ stated that Heather Wilson worked with customers directly and that she was not privy to all meetings that Heather Wilson attended. We asked who would know Ms. Wilson's work efforts. FJ CJ replied that the end-users would know specifically what was requested of Heather Wilson. SJ had stated that she set the parameters for the consulting agreement. We asked her to expand on what was meant by parameters. She replied that she reviewed the procurement guidelines and the Review of Contracting Issues at Los Alamos National Laboratory the invoices.AS3.a She stated that the invoices were broad because they did not have task orders at the - . id that she received assurances from the end users that the consulting services were provided. stated that this information has been ca_tu red in a spreadsheet and was sent to the inspector General. W- - firued that the assurances 5) eceived from the end users was informal and, once received, (W) approved the invoices. We asked if the invoices were in compliance with the FAR requirements. 5) T) CJ replied that she was not familiar with the FAR requirements. We asked i 6) remembered r_ece ving an e?mail from the Buyer discussing what was needed in the memorandum ofjustification. 0?)?ch confirmed that she did receive the email, but couldn't remember what was done as a result of the e-mail. She stated that the memorandum ofjustification tor the CPA was much more extensive. We asked about the determination of a fair and reasonable rate of pay. 5] reolied_thai' the SCH is responsible for making this determination and that it is not something a SDR does. libido 03)?th stated that she was not involved in the rate negotiations. a We asked cJ if she directed the Buver not to contact Heather Wilson. She replied that she could not recall making this direction and that it might have come from some other source. Conclusion: Notes: Results 4: names SNL Purpose: Procedure Step: Source: Type: Assigned To: 33% Scope: Prepared By: (C) 6f6f2014 Reviewed By: (None) Methodology: PROPERTIES: Details: Location: Frequency: Record of Work Done: Review of Contracting Issues at Los Alamos National Laboratory Sample Size: TSumm?irv-C - .. Conclusion: Notes: Results 4: A.9.PRG - SNL Purpose: (bile) lb) Procedure Step: (THC) Source: Type: . Assigned To: Scope: Prepared By: EIEIZUM Reviewed By: (None) Methodology: PRUPERTI ES: Details: Location: Frequency: Record of Work Done: 6 a) TJ Category 4: On October 25, 2012, Inspectors 03K JbemE Iinterviewed [344 User Category: EEJKEJ U33 lat Sandia National La boratorv. The interview took place at the IPOC Building. conference room Category 5 3130.5andia National Laboratory. The purpose of the interview was to discuss a consulting subcontract Category 6 880974] awarded to Ms. Heather Wilson hv Sandia National Laboratory. The interview was basically as follows: SCORECARD: Rating: We asked what organization (W) nelonged to and the duration at this osltion. She replied that she EEJETJ has been a Bu er for 10244 for approximatelv one vear and that her EEJEUECJ rior to this (W3 (WU tated that she was a Buver for 10246, wW?bm] statec that she no longer Issues consulting contracts; that task is under 36] purview. We stated thatmas th 3 6] on a cons ltant agreement 3809?4} issued 1f4f2009. We as e- ow the contract came to be. 9391(6) (thr'J replied that she received a request from the SDR and she processed the agreement in a normal fashion. We asked-if she was involved in anv discussions prior to the awarding of the contract with Heather Wilson- She replied that she was not involved in any discussions prior to the award. We asked who decided on the tvpe of contract to use? replied that she was instructed bv 033(5) 033010 that there would be a Purchase Request coming to her and Review of Contracting Issues at Los Alamos National Laboratory "Summary that she would place the request as a consultant contract. We asked if the consultant template was used. $31353 (WW replied that the template was used and that Ms. Wilson was providing standard consultation to provide ac vice and guidance to Sandia. We asked if the contract was sent to NNSA for review and approval. _eplied that at the time the contract was issued, they did not need to go to NNSA for approval. We stated that there was language throughout the documentation that refers to this arrangement as a retainer and in other areas as a consultant agreement. We asked what tvpe of contract was issued- (him I IUDJEEJ replied that the retainer language was not in the Statement of Work. She stated that the monetarv amount {rate of pay) was alreadv ore-negotiated 5] 7) Cl when she recived the Purchase Request. We asked if a memorandum ofjusti?cation was issued for the contract. 6) '3 replied that the memorandum and rate justification are one in the same for the contract and that a memorandum of justification was done. We asked about the rate of $10,000 paid the Heather Wilson. 6) stated that paving a rate was not uncommon. However, she also stated that this was the first time she had seen a rate and that she had not seen the use of a rate before or sinceasked where the specn?Ic language was in the contract that referred to dehverables and invoices. 7 (335,6.me eplied that some consulting contracts don?t have deliverables unless the reouestor wants a white paper or perhaps a summarv report. She stated that if it's not in the Statement of Work. then the requester didn't specifv a deliverable. We asked who the requester was for P0 a. _replied that it would've been eltherlibjmj (b33333) I She stated thatmwas the individual who submitted the Purchase Request and was listed as the re uestor. We stated that the FAR specified that there be details in the work that was to be performed. 033(5) (bit?) replied twat perhaps that is why the contract was switched to a service contract and it went to (W) We asked if the CPA was a service contracti?f??J Mil lrep ied that the CPA could be a service contract. She said that it was an unfunded agreement that different oranizations could utilize, in this wav, the organizations could utilize Ms. Wilson?s services. istated that an organization would submit a Purchase Request, which would in turn be attached to the CPA. She stated that their Statement of Work would have to be part of the CPA. in this wav, the same Purchase Order didn't have to be issued over and over again. In 6 II 7 We asked if the Statement of Work was clear and concise. replied that the Statement of Work was clear and concise in that Ms. Wilson was to provide advice and guidance. We asked if the Statement of Review of Contracting Issues at Los Alamos National Laboratory Sample Size: - _suniinarv" Detait .. . 1 Results 4: A.B.PRG - SNL Purpose: (bJ Procedure Step: Source: Type: a Assigned To: gig Scope: Prepared By: ECJ 2014 Reviewed By: {None} Methodology: PROPERTIES: Details: Location: Frequency: Record 1? Work DoneCategory 4. On Januar 24 2013. Inspector conducted an interview 0 Sandla User Category: 6) '3 ?3 CJ Sandia National Laboratorv. The interview took place at the building, room lat-3115. Category 5 The purpose ofthe interview was to discuss revision 5 to Sandia's Contract Purchase Agreement. The Category 5 interview was basicallv as follows: SCORECARD: In revision 5 of CPA SUSHI, the following language was inserted: "Task Orders shall contain a requirement Rating: for a deliverable such as a Progress Report or statement of completion of work for the task order. and indication of which tasks are ongoing, and what progress has been made on the ongoing tasks" I asked who was responsible for placing this language in revision 5. 6] esponded that the SDR's were responsible for placing the Statement of Work language into revision 5 of the CPA. ASPHEI confirmed that the sorts for the out waders more entries (were Istated that?as also listed as a EUR. i asked why the wrote this nortion of the CPA. She replied that they were in the best position to write the statement of work?stated that, as the SCR, she reviewed and approved the Statement of Work. In 6 II 7 I asked hat her role was forissuance ofthe CPA and its subsequent revisions. She replied that she prepares the documentation for the CPA?ether than the Statement of Work?end sends it to Policy Iandlbei?J I She said that they then send it to the Sandia Site Office for approval. be ieved thatlibJEESJ (b30383) Iapproved the revision. lasked if it was possible that was involved with drafting the Statement of Work. She replied that normaliv the Site Office does not interact Review of Contracting Issues at Los Alamos National Laboratory 350mmary-' Detail .. . - . with just the SDRs draft the Statement of Work. . . I asked why the Statement of Work was changed so substantially in revision ?ve. ECJ replied that. although the CPA was a service contract, they acknowledged that the contract had its roots from a consulting agreement. She said that they tried to adhere to the policies that govern consultants. Wtated that they sent the CPA for NNSA approval because it went over $100,000. lthen explained to that the language in revision 5 did not make it into the subsequent Task Orders. She agreed that the language should have gone into the Task Orders and did not know why this did not occur-believed that we should discuss this matter with the SDR's. We then discussed the Task Orders. noted that the tasks assigned to Ms. Wilson were either exactly the same or very similar for months at a time. asked-ifthis was typical for consultant?cor tractors. She stated that it was typical, especially since task orders were being placed 6) stated that they would generally place an on-going task into the order until the task was done. [then asked how one would receive assurance that the tasks and deliverabies were completed with these types of task orders. She stated that a progress report would give one assurance on the progress and completion of a task. stated that in February 2010, Ms. Wilson was paid $8000 and in May 2010. ste was paid $4,500. I asked why the amount was decreased since the CPA was firm fixed price 03]? replied that they knew they were getting close to the $100,000 threshold and they needed to go to the NNSA for approval. Therefore, they limited the dollar amount to $3000 in February and no work was conducted in March or April 2010. She stated that some work had to be done in May, so they issued a small Purchase Order for 545000 as a stop gap measure. (aim 033(7) stated that once Sandia received approval from NNSA they re-started payment to Ms. Wilson. Conclusion: Notes: Results 4: A.9.PRG - SNL Purpose: Review of Contracting Issues at Los Alamos National Laboratory Procedure Step: IMSJ (WW) I Source: Type; Assigned To: gig Scope: Prepared By: (Ci of 6! 20 14 Reviewed By: {None} Methodology: PROPERTIES: Details: Location: Frequency: Record of Work Done: Category 4: On January 29, 2013, Insloect_interviewedlfIDJEESJ [b30333 [285- User Category: with Sandia National Laboratory. The purpose of the interview was to discuss revision 5 of Contract Category 5 Purc ase Agreement 9051?1 awarded to Ms. Heather Wilson by Sandia National Laboratory. The interview Category 6 was basically as follows:E.3.PRG SCORECARD: I stated that Sandia changed the boiler pla the CPA but did not change the CPA to a Consultant Rating: Agreemerrt. I asked why this wasn't done Jim; in?) Feplied that there would not have been any benefit Sompre Size: to change the CPA to a Consultant Agreement. i asked if the changes to the boiler plate changed how the CPA was carried out. 6] stated that she did not think that there was any change in how the CPA functioned. I asked why the changes were made to the boiler plate. She replied that Sandie Site Office saw the contact as advisory and believed that the change to the language was a better fit. I stated that there was a Marci: orandum issued by the Site office that discussed the use of ?prohibited activities.? I asked 6] if Sandie provided a written response to the memorandum. She replied that Sandie did not provide a written response to the memorandum. I asked how this lSSue was resolved. She replied that Heather Wilson agreed to the language in the CPA which discusses Prohibited Activities'Mstated that there is clause_in the CPA which prohibits interactions done to obtain or facilitate 'business oppordunities. However-stated that it doesn?t prohibit any interactions with outside entities. I aske-how would Sandie andfor DOE receive assurances that Ms. Wilson {or any other consultant] was not in violation of the Prohibited Activities clause. She replied that the SDR would be res onsible for monitoring their activities. I asked how this monitoring would be accomplished. (EJKPJ (bi I 33303 lrepiied that the SDR would use the reports on what the consultant was doing for each task . She said that there were diSCussions between the Buyer, the SDR and Heather Wilson. _stated that it was made clear to Ms. Wilson the boundaries on Prohibited Activities and that Ms. Wilson reviewed the CPA with a "fine-tooth comb." laslced ifthese discussions were documented. (W) replied that Review of Contracting Issues at Los Alamos National Laboratory - - - Detail . - i . .. - - reference to the CPA and by reference in the consultant boiler plate. I requested the language from the consultant boiler plate. This was provided at a later date {see XX). Iwent over the language in revision 5, which states that Task Orders shall contain a requirement for dellverablea. She confirmed that the deliverable requirement was supposed to be specifically expressed in the Task Orders. I ked who was responsible for ensuring that the Task Orders contain the requirement for a deiiverablehre lied thatthe SDRs were responsible for ensuring that the Task Orders contained the requirement. I asked ,Ti? _if Policy conveyed this requiremen? to the SDRs She replied that she remembers having interaction with the SDRs on this requirement. I asked (W) if there was any documentation on the interaction. She stated that she would check. {inspector's noteiibli?l lcould not obtain any documentation on the matter. See I asked 6] l' Cl how Sandia addressed the issue that the Site Office brought up on the need for the consultant to SUpport their costs with work products, and related documents, subjects discussed, minutes of meetings, and various memorandums and reports. She repiied that it was resolved with the requirement of Progress Reports. we discussed cost reasonableness. The Site Office stated: "in a fixed price arrangement with undetermined tasks and associated travel, how is Sandia determining cost reasonableness as it was not clear what Sandia was going to get for the minimum 50 hours per month.? I asked how was this resolved. She replied that Sandia added more clarification to the $200 per hour that Ms. Wilson was to work. We discussed the fact that the Site Of?ce stated that the FAR requires invoices have sufficient detail, such as the time expended and the nature of the actual services provided, that was not required in the Purchase Orders. I stated that the invoice requirement never changed in the CPA ard or Task Orders. Therefore, additional detail to the invoices was never required of Ms. Wilson. I askedw?l MUECJ Ihow was this issue resoived. She replied that we alreadv discussed the fact that Ms. Wilson refused to provide an accounting of her time in the invoices that were submitted- _tated that this was a unique situation and that she would hate for the issues identified with this CPA to cause wide?spread changes in how laboratories are to utilize consulting services. I stated that the Site Of?ce made a statement to Sandie that thev should request "copies of Wilson?s work products to date to review in assessing the nature of the advisory role and the reasonableness of costs- It is recommended that Sandia review task orders and invoices for Work alreadv performed to date and analvze the work product, the specific task orders and invoices to help answer some of vour concerns.? I asked 933% 03) Review of Contracting Issues at Los Alamos National Laboratory Summary: .. 0316) lb) if Sandia made this request to the contractor- She replied that she believed it was done- I requested the information which was subsequently provided [see I stated that the Site Of?ce questioned the real value added to the mission at Sandia with regards to entering into a contract with Ms. Wilson. According to the Site Of?ce, it appeared from the Statement of Work and the Memorandum of Justification that there were a number of resources cqulg Erotide these services at a lower cost to the government. I asked if this topic was discussed further. 6] replied that nothing happened other than the removal from the Memorandum of Justification language related to Sandia being an intellectual center forissues. i asked ifrevision 5 sent to the contractor for approval and, if so, was it approved and signed by Heather Wilson. 6) '3 Cl con?rmed that the revision was signed off on by Ms. Wilson, either bv hand or due to the fact that she continued to do the work {which indicates acceptance of the changes to the Concfusion: Notes: Resorts 4: A.10.PRG LAN Purpose: asaa Procedure Step: 033(6) (will Source: Assigned To: Prepared By: (Inn 6f6f2014 Scope: Reviewed By: {None} Methodoiogy: PROPERTIES: Location: De torts: Frequency: Category 4: Record of Work Done: (We) . . . 6 UserCategory: On October 22, 2012, Inspector conducted a telephonic Interview of (loll Review of Contracting Issues at Los Alamoa National Laboratory Summar ,gataahj?I if 6J CJ Category 5 I I Los Alamos National Laboratory (505? 663(- ch The purpose of the interview was to Category 5 - discuss a consulting task order awarded to Ms. Heather Wilson by Lee L. The interview was basically as follows: SCORECARD: Rating: The inspector General' 5 Of?ce noted that In the (Draft) Statement of Work dated March 31, 2009, which was Sample Size: part ofthe proposed Heather Wilson consultIng contract there?was language" 'ipetlverables?e However (7 1grocdrement, legal and the Director' 5 office all worked on the Statement of Work (W) tated that he was unsure who actually removed the language I asked if the decision to remove the language was a conscience effort. He replied that they were trying to follow what Sandie did when they set up their arrangement -tated that they did attempt to draft a Statement of WorkJ'Task Iii-ardent. However, they couldn' find an individual who would act as a technical sponsor to commit on a babaith_ lstated that a decision was made to have a broad Statement of Work that would cover all areas. i stated tha EthrJ ad discussions with Heather Wilson on the submission_ of a detailed account of her time which she refused. asked lithe Statement of Work on DeIIverabies was'pulled and-not} alaced lathe" I finai SQW because of these discussions. __l-Ie replied that it; could?ve been reiated however I I rega_ll. H. 1. PEG 1 stated that Ms. Wilson was very direct with him stating that she was not going to account for her time in any detail?b _aicl that it didn't look like they couid realistically do a statement of work, with neing the (W) He said Ms. Wiison would be working in the . Jt Jt lntelIIgence field and that they wanted to get sogeone from Global Security and National Security to be the TechnicalSponsor and provide monthiy tasks. However, the coyidntI find sponsors. 5) '3 3 stated that the Director wanted an agreement with Ms. Wilson, ltook the lead on getting the agreement done. (th?J (bJ replied that he cooldn' ?t remember ekactly who removed the language He stated thit iffcIals rwithIn The Inspector General's Office noted that lwas concerned about deliverables, especially with regards to FAR Specifically, he asked aboUt the actual deliverables that Heather Wilson was going to provide as well as the workfreports LANS expected to receive. LAMS response was that de? 1 would be established in individual task assignments. I stated that this was not done and asked rays] why it was not done. He replied that it was originally anticipated that they would establish individual task assignments, but it was later decided to have a broadEr Statement of Work. EEJJEGJ (WW stated that this was discussed wit 0?15)lele and that he didn't object to their approach. Review of Contracting Issues at Los Alamos National Laboratory summary-r withIM?J MJJECJ Iwho informed them that Sandia already had a contract with Heather Wilson. I hm Istated that Ms. Wiison was paid a fee in a retainer-type agreement and that the statement work was generic. In addition, the deliverables consisted of meeting and phone calls: there were no "hard" deliverables required of_ Ms. Wllson mutated that they were more interested in ideas. - .s 1.13?" i we- said that during the period of perform-lancer there was no expectation that deliverables would be provided. H.1.PRG 5J JJ CJ aid that he knew the agreement would raise eyebrows; therefore, when the task order was issued, he designated himself as thelbeE?J stated that he didn't believe in handing off the areen-ent to others because someone might have to answer to people like the Inspector General?stated that he stands behind the agreement and believes that the laboratory got value from the agreement. He stated that Heather Wilson has a lot of integrity and that as soon as she announced her candidacy for the Senate, she ended the relationship with the laboratory. We asked who specifically did Heather Wilson approach concerning a consulting agreement. 6) replied that Heather Wilson approached -J 6J -J directlv and ro osed an arrangement. 6J JJ tated that Ms Wilson said ?Her 5 Jihad; leccajp help you.? EEJEJJECJ lsaid, however, that he was not privy to the original conversation with He stated that she had clients that Included "three letter" agencies and also conducted training components for National security policy. He said that Ms. Wilson mentioned that she had work with Sandia. We asked how the pay was determined. replied that they used Sandia?s rate. He stated that he probably wouldn't have started at that rate. U. REJEGJEEJEUECJ Israieamatigeem Mathews) lthe (anaemic; IPrimary Weaponsl?bJ??JEbJE JECJ aaoitotbimto (EJKEJJ E'i?leithIUi?J??J (JDJUJKCJ Iall Ms. Wilson's services (bJ? JKCJ Istated thatlbemJ (in leas a recent security hire bylimeJ land that bringing In Heather Wilson was a good fit. lhe Sole Source Justification and identi?ed himself as the SJ JJ CJ lsaid that he thought Heather Wilson's efforts would cut across the laboratory {weapons security, global security, and Congressional relations}. He stated that he aiso knew that there was a risk that there would be outside interest in the areement and again referenced his appointment as this "insulated against the risk." _again stated that he knows the laboratory got value and believed it to be commensurate with the doliar amount paid to Heather Wilson. After being informed that Review of Contracting Issues at Los Alamos National Laboratory Summary.- - - . Sandia' 5 customers might want. lassumed that Sandia wouid be aware ofthe work HWC, LLC was performing for Los Alamos in order to avoid any possibility of duplication. He was surprised to learn that the Los Alamos task order was not issued through Sandia. We discussed the Sandia CPA. 6) JJ CJ stated that he didn't know if there was any coordination (bits) Eb) between Sandie and LANL. He thought that perhaps this was why the payment and invoice was so lax. 5J JJ tated that typically the people who hold the paper are the ones that make the payment. After being shown that LANL indeed made the payment, he stated that he would dig further with the EJEJKEJ . . r' In] 6] EJEJ (bite) We asked If he was familiar with a power point type presentation put to- discuss potential issues and risks associated withawarding a contract to Ms. Wilson. SJ TJ CJ that it was probably brought stated that they went to the government officials and talked to them about it- That is how it was decided to go with the Sandia agreement. ns 5 In UJJUJ said that he was unaware of what action had been taken to address the specific issues a i (bite the power point presentation and was unsure I was ever briefed. In fact he said that he did not believe they briefed SJ CJ Instead he [th land beK lsat down and found a way to get government buy In on an agreement with Ms. Wilson. l?bJ??J JKCJ Istated that hetook too much comfort" In the Sandia agreement. He stated that he also assumed that since the contracting officer approved the use of the CPA if LANL followed it, they would be We asked if he ever had any conversation Ireplied that he thought that there were discussions with We askedbeE?JJ Iif he was aware that officials from DOE Headquarters were involved. He replied that he was not aware that Headquarters was involved We asked if a market survey was done when preparing the Sole Source justificationEJE?J EJEJJECJ Ireplied that he had a discussion with Heather Wilson on her pay in relation to the CIA. In the end, they relied on the rate Sandie paid to Ms. Wilson. SJ JJ CJ reiterated that he was "nervous" on the invoices. He stated that he couldn?t remember approving the invoices. He said that he has an assistant who oes through his e-mails and that perhaps she EJEGJ might have approved the invoices on his behalf. stated that the invoices may have been approved without actually going through him. Review of Contracting issues at Los Alamos National Laboratory Conclusion: Notes: Results 4: A.ID.PRG - LANL Purpose: Procedure Step: (bit?) Procurement Source: Ty 34 (C) ?5 033(6) To: (133(2) Scope: Prepared By: ?3 2014 Reviewed By: {None} Methodology: PROPERTIES: Details: Location: Frequency: Record of Work Done: Category 4: Date Location: October 22, 2012 at 1:00 PM User Category: Conference Room 3011F Category 5 125 Central Park Square, Los Alamos, NM. Category 6 Parting?ants: (W) 03]thth scoaecaeo: loco) 505-555 Rating: PMCJ Isos~ser M5) M13 Sampre Size: one Audito 903% (?31 LosAlamos Audit Group, sos?ssri ?3 Purpose: To discuss and review the POIS {Procurement Orders imaging System) for information Specific to the consulting subcontract with Heather Wilson (eorr 25054?001?09). 516) a; r] C) (2K6) Eb] an-explainecl that PDIS is a record archival system which provides a centralized data repository for acquisition and has been in place at LANL for a couple of decades. The system stores contract Review of Contracting Issues at Los Alamos National Laboratory 1-S-ttmmary information manually entered, generally through scanning, and data drawn from other computer systems. Information maintained in the system are documents scanned from the contract file following contract closing. As documents are entered, a record is created. If items are re?scanned an additional record is created as there is no option to delete a record. Data maintained in electronic ?les on other acquisition computer systems, such as IAS {Invoice Approval System}, is available through POIS. For example, a SubcontractAward, Purchase Order Internal Correction is an electronic record for which there is no hard copy. Through POIS a user can access this data and print it it necessary. PDIS prints a watermark on the page indicating that the hard copy is for convenience and no signature is required. System access is restricted by Eli, based on need to know and is limited, in most cases to, read only. Procurement Specialists should have inquiry access and only one individual has access to add a file through scannins 003(5) We proceeded to look e;itically at the record for the consulting subcontract with Heather Wilson, F'Uit asoss?ool-oa. M5) Mil logged into the we and observed that his aCCess was limited to "find? and ?print? . stated that her access is similar and that she does not know of anyone who has any access other 1an rea only {not edit), with the exception of the individual tasked with scanning closed subcontracts. Under the Ind" a user can enter a Specific PD number or choose from a menu of other computer systems, i.e. 1A3, PEAS and PRIME, on LAMS restricted access network. Upon entering the PO number, we a two records for subcontract. Bot1 had been entered through scanning on Oct 5, 2011 bi?'vholfIDJEISJ Cb] 92(6) (We) identified asIEg? a We reviewed both {Tiif?l records quickly. The records apnea - - be dupiicates and each of the same size, 299 pages. No differences were noted between what was in the PDIS system and what was provided to the inspection team previously. 033(6) moved among records in the system, a log of items requested tor the day was maintained on the primary access screen. In res onse to inquiry as to whether a log of items viewed beyond this day was maintained, bothlEElE?J stated that they did not think so but rather the log was for the user's convenience. Both suggested I ask EbJE6J I for confirmation. Review of Contracting issues at Los Alamos National Laboratory summary I 6) a . . NeitheriiJECJ nor J: chould answer questions regarding detailed system Information, such as logs or record changes. Both believed data and documents maintained in the POIS were unalterahle. again, they suggested I Speak to 333(5) With that our discussion and review of the POIS system concluded. Conciusion: Notes: Resuits 4: Purpose: Procedure Step: (W) Source: Type: Assigned To: gig Scope: Prepared By: 6/5i2014 Reviewed By: {None} Methodoiogy: Detoiis: Location: Frequency: Record of Work Done: Category 4: Date a Locaticin: October 25, 2012, 2:00 pm, telephone conversation User Category: Cot?gory 5 Participants: s] i] GIG AuditoilEEiEg (b3 Los Alamos Audit Group. {505) 65? 5J CJ SCURECARD: Rating: Purpose: Sampie Size: To determine POIS {Procurement Orders Imaging System] capabilities met I explained that POIS is an archive system with inputs oidata from other computer systems or scanned documents. Data entry control points include the systems that feed into P013 and a few scanners.