Review of Contracting Issues at Los Alamos National Laboratory Sumniarff-?C3 Detaii . . PROPERTIES: Details: Location: Frequency: Record of Work Done: Category 4: User Category: Conclusion: Category 5 Category 6 Notes: SCORECARD: Results 4: Rating: Sample Size: D.3.PRG - SNL Purpose: Procedure Step: invoices not in line vii/FAR We: (state) Assigned To: Prepared By: 6} 20 14 Reviewed By: {Nor e) PROPERTIES: Location: Frequency: Category 4: User Co tego ry: Category 5 Category 5 SCORECARD: Rating: Sample Size: To support the statements in the report: "Similar to the issue with the lack of deliverables, we determined that responsible contracting officials did not incorporate the invoice requirements of the FAR into the Purchase Agreement with HWC, Source: Scope: Methodology: Details: Record of Work Done: The FAR 31.20583, Professional and consultant service costs, Section if], states that fees for services rendered are allowable only when supported by evidence of the nature and scope of the service furnished. Evidence necessary to determine that work performed is proper and does not violate law or regulation includes: Section invoices or billings submitted by consultants, including sufficient detail as to the time expended and nature of the actual services providEd (emphasis added} i We found that there was no evidence of deliverabfes and detailed invoices to support the allowabilitv of these payments by Sandie to Heather Wilson (ESPRG i. Although Sandie did have invoice requirements in Review of Contracting Issues at Los Alamos National Laboratory Summary '5 fibetait' .-: . . - the CPA bookmark we found that no requirement listed in the CPA appiied to Heather Wilson's contract. for discussion Therefore, although required by the FAR, Sandia did not flow these requirements down to Heather Wilson's contract and we can state; Similar to the issue with the tack of deliverables, we determined that responsible contracting of?cials did not incorporate the invoice requirements of the PM into the Purchase Agreement 1iivith ch, LLC. Conciusion: Notes: Resuits 4: D.3.PRG - Purpose: Procedure Step: No direct evidence Tree (bite), Assigned To: Prepared By: (C) artifact-4 Reviewed By: {None} PROPERTIES: Location: Frequency: Category 4: User Category: Category 5 Category 5 SCORECARD: Rating: Sample Size: Sandia, hawever, did not present us with direct evidence and, as such, this information was not sufficient to support the payments made to HWC, LLC. Source: Scope: Meta odoiogy: Detaiis: Record of Work Done: Sandia provided the Inspector General a spreadsheet that compiled the various activities that Heather Wilson conducted tag). In addition, the primary SDR stated that Heather Wilson's deliverables were meetings, discussions [many which were classified}, participation in advisory panels, planning sessions, and the National Securitv Speaker Series. However, the FAR 31.205?33, Professional and consaitont service costs, Section if}, states that fees for services rendered are allowable only when supported by evidence of the nature and scope of the service furnished. Speci?callv, Section if} requires that consultants provide work products and related documents, such as trip reports indicating persons visited and subiects discussed, minutes of meetings, and collateral memoranda and reports (ass i. I- Review of Contracting Issues at Los Alamos National Laboratory jy'mmarv' _oetau- The primary SDR A393, bookmark 2) stated that there wasn?t a white paper, reports or hard copy deliverables associated with the No tangible deliverables that meet FAR reouirements were provided to the Inspector General's Of?ce- Therefore, we can state that "Sandie, however, did not present us with direct evidence and, as such, this information was not suf?cient to support the payments made to HWC, LLC Procedure Step: no detail invoi Type: Assigned To: gig Prepared By: (C) ces Nevada srorzola Reviewed By: iniou PROPERTIES: Location: Frequency: Category 4: User Category: Category 5 Category 6 SCORECARD: Roth: 9: Sample Size: i Con ciusio n: Notes: Resui?ts 4: Nevada Purpose: To provide support for the statement in the report: "Also, our review of the agreement found that it did not contain the FAR requirement that invoices or billings submitted bv HWC, LLC include sufficient detail as to the time expended and nature of the actual services provided." Source: To support the statement in the report: "Also, our review of the agreement found that it did not contain the FAR requirement that invoices or billings submitted bv HWC, LLC include suf?cient detail as to the time expanded and nature of the actual services provided" Scope: Methodology: Details: Record of We rir Done: The FAR 31.205?33, Professionoi and consultant service costs, Section it}, states that fees for services rendered are allowable onl?vr when supported bv evidence ofthe nature and scope ofthe service furnished. Evidence necessary to determine that work performed is proper and does not violate law or regulation includes: Section if} Invoices or billings submitted bv consultants, including sufficient detail as to the Review of Contracting Issues at Los Alamos National Laboratory ?nimary . Detail PROPERTIES: Details: Location: Frequency: Record of Work Done: Category 4: User Category: Conclusion: Category 5 Category 6 Notes: SCORECARD: Results 4: Rating: Sample Size: E.3.PRG - SNL Purpose: Procedure Step: summary don?t do business Type: Assigned To: gig Prepared By: (C) 5f6l'2014 Reviewed By: {None} PRO ES: Location: Frequency: Category 4: Use Category: Category 5 Category 6 SCORECARD: Rating: Sample Size: To support the statement: "On a final note regarding Sandia?s handling of the agreement with HWC, LLC, we discovered internal correspondence that reveals how, at least some, Sandia Laboratory officials viewed this particular consulting agreement." Source: Scope: Methodology: Details: Record of Worlr Dorie: 6 (th JUJJE (bit JECJ I both We were provided an November 11 and 12, 2009 e-mall between Sandia National Laboratory officials. In the e-rnall, both officials stated that they didn?t do business with anyone else like this, wi_ ado?idng that he wished the contract would go away (13.9.11! Therefore, we can state regarding Sandia's handling of the agreement with HWC, LLC, we discovered internal correspondence that reveals how, at least some, Sandie Laboratory officials cleared this particular Review of Contracting Issues at Los Alamos National Laboratory "Summary consulting agreement.AS3.a Conclusion: Notes: Results 4: Procedure Step: no del requirement Type: Assigned To: Prepared By: (WHO) 5f6f2014 Reviewed By: (None) RD PERTIES: Location.- Frequency: Category 4: User Category: Category 5 Category 6 SCORECARD: Rating: Sample Size: Purpose: To document the statement in the report: "While Sandia broadly outlined the tasks to be performed in its Purchase Agreement with ch, LLC, it did not initially include requirements for speci?c deiiverables. Our review found that from March 2009 until May 2010, there was no reference to deliverables in the Purchase Agreement." Source: Scope: Methodology: De toils: Record of Work Done.- ln it?s original Contract Purchase Agreement 9051?1 Revision 0, the Statement of Work broadly outlined tasks to be performed by Heather Wilson. However, the sow had no discussion on deliverables gage 5 redbox). CPA 9051?l went through four subsequent revisions, with no deliverable language added (A914). Deliverable language was ?nally added in May 2010 (A013 bookmark ll. Therefore, we can state that "While Sandie broadly outlined the tasks to be performed in its Purchase Agreement with HWC, LLC, it did not initiatlv include requirements for speci?c deliverables. Our review found that from March 2009 until May 2010, there was no reference to dellverables in the Purchase Agreement." H.1.PRG Conclusion: Review of Contracting Issues at Los Alamos National Laboratory _S_ummar.v- incorporated in the Purchase Agreernent was never included in anv of the subsequentlv issued task orders."A53.a Because even after Federal of?ciats at the Sandia Site Office identified the lack of deliverables as a concern and directed inclusion of specific deiiverables in the task orders {19.32. bookmark 2 and A313. bookmark 1), Sandie changed the CPA A313 bookmark but did not incorporate the langauge in the task ordersi we can also say contractor officials failed to fully comply with the direction. Procedure Step: no deliverables Tm?" (we) Assigned To: (are) Prepared By: 5/53? 1?4 Reviewed y: E5: Location: Frequency: Category 4: User Category: Category 5 meteoriter 6 5CD REGARD: Rating: Sample Size: Conciasr?on: Notes: Resutts 4: - SNL Purpose: To support the statements in the report: without the evidence of deliverables and detailed invoices to support the allowabilitv of these payments; and However, we determined that HWC, LLC was paid the $10,030 per month without submitting deliverables to the designated 5a ndia Delegated Representatives (SIDES). Source: Scope: Methodoiogy: Detoii?s: Record of Work Done: The FAR 3 1205-33; Professions! and consur?rant? service costs, ,3 states that fees for services rendered are allowable onlv when supported bv evidence of the nature and scope of the service furnished. Evidence necessatv to determine that work performed is proper and does not violate law or regulation Review of Contracting Issues at Los Alamos National Laboratory Sampie Size: summary ?es-ailand' Invoices (D. 3. We were also orovided task orders associated with Heather Wilson's Consulting SCORECARD: Agreement with Sandia In addition, Sandie conducted a search for evidence of the services Rating: provided lav HWC, LLC and developed an after?the?fact schedule of activities [Mi This information is considered to the the relevant contract file. Within all of this information, we found that there was no information on deiiverables {mi as defined by the H.1.PRG Conciusr'on: Notes: Results 4: E.3.PRG - SNL Procedure Step: No monitoring Type: Assigned To: (Wig) Prepared By: Ef?fzoiti Reviewed By: (None) PROPERTIES: Location: Frequency: Category 4: User Category: Category 5 Category 6 SCORECARD: Rating: Sompie Size: Purpose: To support the statement in the report: ?However, during our inspection, we found no documentation of this claimed monitoring." Source: Scope: Methodology: its: eto (bii5ir(5)(Ti(Ci Record of Work Done: We interviewed thel Ifor the CPA with Heather Wilson. She stated that she coordinated with the end users to a certain extent. (W) JECJ tated that sometimes Heather Wilson would work with the end users directlv. in these cases, (W) said that she would be informed of these meeting by either Heather Wilson or the end user Therefore, some monitoring may have occurred. However, in a review of the contract file, it did not contain any evidence of monitoring lav the end users, Review of Contracting Issues at Los Alamos National Laboratory Procedure Step: No delivera bl es rsininumio:._ . Detail E.5.PRG Dakrid ge Purpose: To support the statement in the report: "In response to an Office of inspector General request for deliverables at Oak Ridge, we were told that there were no deliverables or other written products generated ProcedureStep: unusual circumstances Type: (hire), as a result of these agreements." Assigned To: Prepared By: (C) sis/2014 Source: Reviewed By: {None} Scope: PROPERTIES: Location: Methodoiogy: Frequency: Category 4: De toiis: User Ce tegory: Categorys Record of Work Do me: . Category 6 The DIG contacte- Contracting Officer, DOE ORNL Site Office- In resoonse to our request for information, he stated that the were no written deliverables with regards to Battelle's contract with Heather SCORECARD: Wilson E.5.1 and Rating: Sompie Size: Con ciusi'on: Notes: Results 4: F.1.PRG - Subobiective - Pressure Purpose: Support for the statement: ?As outlined in this report, the circumstances surrounding the award and execution of the HWC, LLC consulting agreements were unusual and, in some instances, highly irregular.? TYPE: Assigned To: (bilelalbl Prepared By: (THC) EXEIZOM Source: Reviewed By: {None} Scope: PROPERTIES: Location: Methodoiogy: Review of Contracting Issues at Los Alamos National Laboratory Summary - -- - - -- Detaii" Frequency: Category 4: Details: User Category: Category 5 Record of Work Done: Category 6 In the report we state that Los Alamos requested to enter into a separate consultant agreement with HWC, LLC, but that the request was denied by the Los Alamos Site Office Contracting Of?cer {see and SCORECARD: Rating: We also state that in order to address a concern for duplication, Los Alamos was directed to use Sandia's Sample Size: Purchase Agreement that was already in place for the services of HWC, LLC Finally, we state that Los Alamos was authorized to issue task orders against the Sandie Purchase Agreement lass. bookmark 5 A443, bookmark 2). The way the Los Alamos task order was approved was unusual. Specifically, the ?ontracting Of?cer for the Los Alamos Site Office stated that this was tho only time something like this had been done A.8.PRG). the execution of LANL's task order and Sandia?s CPA was flawed. Specifically, there were numerous de?ciencies in how Sandie tasked Heather Wilson l{ E.3.PRG l, and Submission ofinvoices by Ms. Wilson J, and the lack of any tangible deliverables associated with the task orders and In addition, we found an e-mail where Sandie officials stated that they didn't do business with anyone else like they did with Heather Wilson and they wished the contract would go away and 396.20 for (W5) (me?CJ ~Sandia employee}. With Los Alamos, we found that statement of work language was in a draft, but not in the final statement of work (H.1.PRG and deliverable requirements were never created. The language was deleted from the ?nal task order even though a Los Alamos contracting official informed the NNSA Contracting Officer that deliverables would be established in individual task assignments.lA.3.1 bookmark 1 When we asked for the speci?c taskings from august 20(39 to February 2011, Los Alamos was not able to provide any documentation showing what tasks and activities HWC, LLC was directed or scheduled to perform on a basis.{A.1U.PRG Therefore, we can state: ?As outlined in this report, the circumstances surrounding the award and execution of the HWC, LLC consulting agreements were unusual and, in some instances, highly irregular."A53.a F.1.PRG Review of Contracting Issues at Los Alamos National Laboratory FilmmaM . oetail . . Conciusion: Notes: Results 4: F.1.PRG Subobiective Pressure Purpose: To support the statements in the report: "As part of our fact gathering process, we interviewed the NNSA Procedure Step: no ev dencei pressure officials involved, to include the contracting of?cer." and; Type: (all?) Assigned To: 1 "However, we were unable to identifyr any evidence that the contracting officer was subjected to "pressure" Prepared By: during the approval of the HWC, LLC agreement at Los Alamos.?A53.a Reviewed By: (None) Source: PROPERTIES: Location: Scope: Frequency: Category 4: Methodology: User Category: Category 5 Detoiis: Category 6 Record of Work Done: SCORECARD: We did not identify evidence that an NNSA Contracting Officer was subjected to "pressure" durin _the Rating: approval of the HWC, LLC consulting contract at Los Alamos. Specificallv, we interviewed 033(6) the Sampie Size: Contracting Officer, who alleged that two former Los Alamos Site Office Managers i pressured him into approving LANE request for Ms. Wilson's consulting services {m We interviedwe the two Managers; however, there were no indications that these Managers unduly pressured '353 '17) approve Ms. Wilson's servicesi A.8.PRG and ASPRG [bx Jfbii also alleged that Los nlamos personnel went "behind his back" to receive approval for Ms.- Review of Contracting Issues at Los Alamos National Laboratory o'etaii- Wilson's service pink highiight). While we did confirm that the former site office Managers had conversations with Los Alamos personnel concerning the acquisition of Ms. Wilson's services, there were no indications that these conversations were outside normal business operations or that the conversations undulv influenced the site office Managers to pressure 33(5) (bit?) and - green highlights a NW lleged that bv comparing his original draft memorandum deriving LAN L's request to the actual memorandum that was issued, a large discrepancvr would become evident, thus corroborating that he was pressured into approving the LANL request A.3.PRG While a comparison of the two memoranda and 11.8.5] did not reveal thatl?bzf'??l (bit?) Iwas pressured, it did suggest that the manner in which Ms. Wilson's services was acquired at the laboratorv was unusual i We interviewed relevant personnel and confirmed that the manner of acquisition was unique and executed only for the acquisition of Ms. Wilson's consulting services Con clusi'on: Notes: Results 4: Procedure Step: i ffere nces F.1.PRG - Su_bobiective - Pressure (bite). Prepared By: Assigned TO: PRO PERTIES: Location: Frequency: Category 4: User Cote-go ry: Category 5 Reviewed By: one} Purpose: To suppor the statement in the report: ?While we noted differences in the contracting officer?s draft letter deriving LANE request to enter into a consulting agreement with HWC, LLC and the final denial letter, the denial of the LANS request was upheld and the concern over possible duplication of effort at Los Alamos and Sandie was specificallv addressed by directing LAMS to use the Sandie agreement with HWC, Source: Scope: Methodology: Details: Review of Contracting Issues at Los Alamos National Laboratory Summary - Detail .3Category 6 Record 0 Work Done: *Contracting Officer at the Los Alamos Site Office, alleged that by comparing his original draft SCORECARD: memorandum denying LANL's request to the actual memorandum that was issued, a large discrepancv Rating: become evident, thus corroborating that he was pressured into approving the LANL request gm}. Sample Size: A comparison of the two memoranda (M and Egg; does not reveal the-was pressutEd, there are some notable differences. Specifically, the Draft memorandum Specifies the reason for denying LANL's request. These reasons include that the agreement is reflective of a retainer agreement, that it doesn't identify deliverables, and that didn't conduct a formal market survey or conduct a cost price analysis. The Draft suggests that LANL look into a cost-sharing arrangement with Sandia {m l. The final memorandum does not give reasons for denial; it simply ditects tent to use Sandia's CPA with Ms. Wilson (w Although it may have been beneficial for the contracting officer to voice his concerns in the memorandum, the effect of the draft and the final memorandum was still the same. Namely, that LANL was denied a contract with Heather Wilson. During the interview with the inspector General's Office, ?revealed that by usingthe Cite, it would address the issoe of duplication of efforts as well as cost considerations Blues-shields: Therefore we can state: "While we noted differences in the contracting officer?s draft fetter denying LAMS request to enter into a consulting agreement with HWC, LLC and the final denial letter, the denial of the LANS request was upheld and the concern over possible duplication of effort at Los Alamos and Sandie was specifically addressed by directing LANE to use the Sandia agreement with ch, Conclusion: Notes: Results 4: Summary? Review of Contracting Issues at Los Alamos National Laboratory oataa- Type: Assigned To: Prepared By: Reviewed By: PROP ERTI ES: Location: Frequency: Category 4: Category 5 Category 6 5CD RECARD: Rating: Sample Size: G.1.PRG Subobiective - Duplicative Procedure Step: insufficient documentation to) ejsrzota User Category: {None} Purpose: To document the statement in the report: We found that available documentation regarding deliverables and invoices was insufficient to make a determination on whether or not there was overlap between the services provided and work products produced by HWC, LLC on consulting agreements at Sandia National Laboratories, Los Alamos National Laboratory, Nevada National Security Site and the Oak Ridge National Laboratory. Source: Scope: Methodoiogy: De toiis: Record of Work Done: . At Sandia, the evidence of the nature and scope of the services furnished was significantly lacking. Specifically, 23 payments totaling were authorized for the services of HWC, LLC without the evidence ofdeliverables and detailed invoices to support the allowability of these payments (0.3.1 and E.3.PRG J. H.1.PRG I- At Los Alamos, the evidence of the nature and scope of the services furnished was significantly lacking. Specifically, 19 payments totaling $195,?18 were authorized for the services of HWC, LLC without the evidence of deliverables and detailed invoices to support the allowability of these payments and . We determined that between July 2010 and December 2011, Nevada National Security Site {Nevada} and Oak Ridge Nationai Laboratory {Oak Ridge) paid approximately $30,000 for services rendered by HWC, LLC [0.4.1 D.5.PRG J. Review of Contracting Issues at Los Alamos National Laboratory F'sumrnarv - -. -. . . Without deliverables and detailed invoices, it was not possible for the DIG to determine whether or not there was overlap between the services provided and work products produced bv HWC, LLC on the consulting agreements at the four sites. For example, we could not determine if the same deliverable was being used to support the services provided at more than one site. We also could not determine if the scope of work was duplicated at more than one site, if the hours billed were the same hours bilfed at another site; or if travel in support of the services provided was the same travel reimbursed at another site. Conci'usion: Notes: Resorts 4: G.1.PRG Subobiective - Duplicative Procedure Step.- Primarv users Type: Purpose: To support the statement in the report: The primarv users of the services of HWC, LLC were Los Alamos and Sandia. Assigned To: Egg; Prepared By: (C) 61632014 Source: Reviewed By: {None} Scope: PROPERTIES: Location: Methodofogy: Frequency: Category 4: Details: User Category: Category 5 Record of Work Done: Category 6 ?ute determined that the services provided by HWCJ LLC at these two laboratories accounted for more SCORECARD: than 90 percent of the approximately $450,000 in fees paid to HWC, LLC. Specificaltv: Rating: Sample 5529: . We determined that between Januarv 2009 and March 2011, Sandia National Laboratories (Sandial Review of Contracting Issues at Los Alamos National Laboratory Summary Detail}- . . - .. authorized 23 payments totaling $226,3?8 for services rendered by HWC, LLC 0.3.1 and l. We determined that between August 2009 and February 2011, Los Alamos National Laboratory {Los Alamosl authorized 19 payments totaling $195,?18 for the services of HWC, LLC l. We determined that between July 2010 and December 2011, Nevada National Security Site (Nevada) and Oak Ridge National Laboratory (Oak Ridge] paid approximately $30,000 for services rendered by HWC, LLC The payments at these four sites totaled approximately $450,000 as follows: I {$195,586} {$30,000} $451,694 or approximately $450,000. As seen above, the primary users of the services of HWC, LLC were Los Alamos and Sandia, accounting for more than 90 percent ofthe approximately $450,000 in fees paid to HWC, LLC, as follows: - 0.9342 or more than 90 percent of the approximately $450,000 in fees paid.H.1.PRG Con ciusio n: Notes: Results 4: G.1.PRG - Subobiectiye - Duplicative Procedure Step: no Sandie Process Timer Assigned To: I J6) NC) I Purpose: To support the statement in the report: However, while the language was inserted into the task order, tos Alamos' use of Sandia?s Purchase Agreement did not include a process to avoid duplication of effort. Review of Contracting Issues at Los Alamos National Laboratory Euro-ma?a .- . . Detail Prepared By: gig?: 6f6f2014 Source: Reviewed By: {None}! Scope: PROPERTIES: Location: Methodology: Frequency: Category 4: Detoiis: User Category: Category 5 Record of Work Done: Category 6 SCQRE-CARD: gee?am a July 1, 2009} memorandum to Los Alamos, the Los Alamos Site Office Contracting Officer, per a Rating. request from Sandie, directed Los Alamos to insert a requirement in the agreement to avoid duplication of Sampfe Size: effort. Specifically, the following language was to be inserted into the Los Alamos task order: By accepting this order the contractor acknowledges that the work performed hereunder for Los Alamos National Laboratory is wholly separate from and not duplicatiye of work being performed for Sandia National Laboratories (was Howeyer, Los Alamos' use of Sandia's Purchase Agreement did not include a process to avoid duplication of effort. Speci?cally, Sandie was unaware of the specific seryices HWC, LLC was to provide at Los Alamos as follows: . The Los Alamo assumed that Sandia would be aware of the work HWC, LLC was performing for Los Alamos in order 0 avoid any possibility of duplication 333% Eb] was surprised to learn that the Los Alamos task order was not issued through Sandia. We lound that the Los Alamos task order was issued separate and apart from Sandia A contracting official also confirmed that Sandia was not aware of the specific tasks HWCJ LLC was performing at Los Alamos {name and In addition: Review of Contracting Issues at Los Alamos National Laboratory Summary .. a We were not able to identi?,r anv Department or contractor internal process whereby the four Department contractor operated sites would have been aware that other NNSA sites had awarded consulting agreements to HWC, LLC, and that such agreements were running in order to identify and avoid the possibility of duplication of services and work products provided bv HWC, LLCEG.1.PRG i. As a result of the weaknesses associated with deliverables, invoices and the implementation of the agreement between Los Alamos and HWC, LLC, there was no practical way for the Laboratories and/or the Department to assure themselves that there were no redundant pavments for the same contractor services. Conciusion: Notes: Resorts 4: G.1.PRG - Subobiective - Duplicative Procedure Step: Sandie unaware Purpose: To support the statement in the report: Spebificailv, Sandie was unaware of the specific services HWC, LLC was to provide at Los Alamos. Type." (byte), Assigned To: (till?) Prepared By: (C) 6f6f2014 Source: Reviewed By: {No no} Scope: PROPERTIES: Location: Methodoiogv: Frequency: Category 4: Detoiis: Review of Contracting Issues at Los Alamos National Laboratory summerirv i Detaiis. User Category: Category 5 Record of Wont Done: Category 6 Support: SCOFECARD: 1- The Los Alamosg assumed that Sandia would be aware of the work HWC, LLC was performing for Ratmg: Los Alamos in aia??} avoid any possibility of duplication AJELPRG highlight Sample Size: 0 03mg] Eb] was surprised to learn that the Los Alamos task order was not issued through Sandie. We own at the Los Alamos task order was issued separate and apart from Sandiat A.10.PRG highlight}. I contracting official also confirmed that Sandie was not aware of the specific tasks HWC, LLC was performing at Los Alamos and Conclusion: Notes: Results 4: G.1.PRG - Subobiective - Duplicative Purpose: Procedure Step: no depfcont process To support the statement in the report: In addition, we were not aisle to identify any Department or contractor internal process latherelssr the four Department contractor operated sites would have been aware Type: that other NNSA sites had awarded consulting agreements to HWC, LLC, and that such agreements were Assigned To: (7)03) running concurrently, in order to identify and avoid the possibility: of duplication of services and work Prepared By: products provided by HWC, LLC. Reviewed By: {None} PROPERTIES: Source: Location: Frequency: Scope: Category 4: User Category: Methodotogy: