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Oles Morrison

FY2014 Interagency Suspension and Debarment Committee Report: The Compliance Trend Continues Part 1

By on May 28, 2015 | Posted in Suspension and Debarment

It’s the time of year again to obsess over numbers that are mostly irrelevant. On April 1, the Interagency Suspension and Debarment Committee released its FY2014 report releasing the number of exclusion actions government-wide that agencies initiated. These numbers include suspensions, proposed debarments, and debarments as well as administrative agreements. It’s important to understand how these numbers are compiled before discussing the numbers themselves.

First, if, for example, Suzy Smith and Bobby Smith own Smith Contractors and all three are proposed for debarment for the same misconduct, those are counted as three actions within the ISDC report’s numbers despite only one act of misconduct. The ISDC itself admits that it “does not consider the overall number of suspension and debarments to be a metric of success.” Because most of the actions behind these numbers are unpublished, it is impossible to tell how many actual instances of misconduct the SDOs reviewed this year. Why do we care about instances of misconduct compared with overall numbers? If one debarment covers fifty individuals in a single case, that single case counts as fifty actions, and it looks like there is far more activity in that agency over the year than there actually is.

Second, agencies can only take action against contractors that they are the “lead agency” for. That generally means the agency that has spent the most money with the contractor. The various agencies under the Department of Defense have a much larger budget than the civilian agencies for procurement. This generally means they have more contractors to take action against than the civilian agencies. Furthermore, if there are contractors that do work for the civilian and defense agencies, the defense agencies will likely decide whether or not to take action against the contractor rather than the civilian agencies. This partially explains the discrepancy between the number of actions the civilian agencies take and the defense agencies take.

Lastly, not all actions are equal. This year USAID initiated an action against International Relief and Development, one of its largest contractors. That one action had far more potential to impact USAID’s ability to conduct its mission than many of the other smaller actions that make up the total number of actions the Federal Government took this year. This is not to say that each action is not important to protecting the integrity of the procurement process. However, smaller numbers from one agency does not mean that they are not an active agency.

Now that we have a basis for understanding how the numbers are compiled, in our next post we will discuss the actual results.