OFFICE OF INSPECTOR GENERAL

U.S. GENERAL SERVICES ADMINISTRATION

April 1, 2022 – September 30, 2022

SEMIANNUAL

REPORT TO THE CONGRESS

CONTENTS

1 OIG PROFILE

 OIG Profile

 OIG Organization Chart

 Investigations of SeniorOcials

 Fleet Card Fraud

 WPA Art Investigations

 Other Significant Work

 Statistical Summary ofOIGInvestigations

Significant Recommendations FromPriorReports

 APPENDIX III

Audit and Inspection ReportRegister

 APPENDIX IV

OIGReports over12MonthsOld, FinalAgencyActionPending

 APPENDIX V

OIG Reports Without ManagementDecision

Management Decisions Revised or With Which the Inspector General is in Disagreement

 APPENDIX VII

Reporting Requirements

Cover Photo: GSA Building Exterior

MESSAGE FROM THE IG

I am pleased to submit to Congress our Semiannual Report for the period of April 1, 2022,

This report closes out a fiscal year in which our oce again provided a strong return

on the American taxpayers’ investment in us. During Fiscal Year 2022, our audit and

During this period, we issued to the agency multiple audit documents identifying

we delivered an alert memorandum warning that although GSA was on track to greatly expand that

before re-opening child care centers closed due to COVID-19, and we found that the Public Buildings

Service faces challenges in its eorts to improve air filtration in GSA-controlled facilities to help prevent

workplace exposures to COVID-19.

Our special agents conducted successful investigations of fraud, misconduct, and criminal actions by

contractors and governmental ocials, including an Oklahoma Assistant Police Chief who stole GSA

firearms, an Army Program Oce Director who conspired to defraud the government, and a GSA Real

Estate Acquisition Director who received an illegal gratuity. They also uncovered a variety of procurement

fraud schemes, bringing to justice contractors who made false certifications in GSA’s System for Award

Photo: The Internal Revenue Service Building, located in Washington, D.C.

OIG PROFILE

The General Services Administration (GSA) Oce of Inspector General (OIG)

was established on October 1, 1978, as one of the original 12 OIGs created by

the Inspector General Act of 1978. The OIG’s five components work together to

perform the mission mandated by Congress.

The OIG provides nationwide coverage of GSA programs and activities. Our

components include:

management in evaluating and improving its programs.

 THE OFFICE OF ADMINISTRATION, a professional support sta that provides

budget and financial management, contracting, facilities and support services,

human resources, information technology (IT) services, and administers the

OIG’s records management program.

 THE OFFICE OF COUNSEL, an in-house legal sta that provides legal advice

and assistance to all OIG components, represents the OIG in litigation arising

out of or aecting OIG operations, and manages the OIG legislative and

regulatory review.

 THE OFFICE OF INSPECTIONS, a multi-disciplinary organization that analyzes

and evaluates GSA’s programs and operations through management and

organization that conducts nationwide criminal, civil, and administrative

investigations of illegal or improper activities involving GSA programs,

operations, and personnel.

Headquarters:

Washington, D.C.

Field and Regional Oces:

Atlanta, Georgia; Tacoma, Washington; Boston, Massachusetts; Chicago, Illinois;

Denver, Colorado; Fort Lauderdale, Florida; Fort Worth, Texas; Kansas City,

OIG ORGANIZATION CHART

Sarah Breen

Larry Lee Gregg

Data Systems Sta

Real Property Audit Oce

Information Technology and

Budget and Financial

Photo: U.S. Custom House in New Orleans, Louisiana

FISCAL YEAR 2022 RESULTS

questioned costs. If adopted, these recommendations ultimately result in

savings for the taxpayer.

report that assisted management in improving the eciency and eectiveness

• 3 lost pieces of Works Progress Administration artwork recovered.

agencies, 50 were referred to the OIG Oce of Audits, 2 were referred

to the OIG Oce of Counsel, 1was referred to the OIG Human Resources

2021-05, and only use the 4P tool as part of a larger negotiation strategy that

seeks the lowest overall cost alternative to meet the needs of the federal

Guide to require contracting personnel to conduct additional price analysis

on products for which the 4P tool returns only self-hits; include commercial

market pricing information presented in the 4P tool in price evaluations

and provide justification when the awarded pricing exceeds the lowest

commercial market price found; seek, analyze, and document justification for

product pricing that exceeds the market threshold; and manually research an

appropriate sample of products for which the 4P tool found no market research

comparisons to ascertain applicable market pricing information; (3) provide

training to contracting personnel regarding the use of the 4P tool, focusing on

updated 4P Application User Guide requirements; (4) develop and implement

The FAS Commissioner largely concurred with our report recommendations,

but contended that the methodology used to derive the recommendations

does not substantiate the conclusion that the 4P tool often contains outdated

or inaccurate pricing data. In addition, the FAS Commissioner disagreed with

our report recommendation that contracting personnel should use commercial

market pricing information presented in the 4P tool to evaluate GSA schedule

pricing and provide justification when the awarded pricing exceeds the lowest

commercial market price found.

Report Number A210033/P/5/R22006, dated June 22, 2022

GSA, through its Public Buildings Service (PBS), is the primary federal real

property and asset management agency, with a portfolio consisting of more

systems in GSA-owned buildings are eectively protecting the safety of the

public, employees, and property. We performed this audit based on concerns

over the condition of security camera equipment in GSA-owned buildings

raised by GSA ocials and prior GSA Oce of Inspector General reports.

these issues, little action is being taken to address the situation.

Based on our audit finding, we made two recommendations to the GSA

and(2) addresstherelated funding issues.

The GSA Administrator agreed with our first report recommendation and

partially agreed with our second report recommendation. In response, we

made certain revisions to our second report recommendation.

In May 2022, we initiated an Audit of GSA’s Response to the Coronavirus

eectively test for water contamination prior to reopening GSA child care

centers that were closed during the pandemic. The purpose of this alert

memorandum was to notify PBS of this concern.

GSA’s child care center program provides space in GSA facilities across the

nation for 92 independently operated child care centers. Prior to COVID-19,

these centers provided daily care for more than 7,000 children. In response to

The Centers for Disease Control and Prevention (CDC) guidance states that a

temporary shutdown or reduced building operations and decreased water use

release of lead and copper into the facility’s drinking water. Stagnant water can

also increase the risk of growth and spread of Legionella bacteria. Exposure to

these contaminants can lead to serious health problems.

in 38 of the 71 child care centers that were previously untested. The testing

identified contaminants above the Environmental Protection Agency’s action

Colorado; and Ogden, Utah. As of June 2022, the remaining 33 child care

centers remained untested. Moreover, PBS’s water testing has not been

comprehensive because it did not test for potential contamination from

Legionella bacteria.

Water testing in child care centers is critical to ensure that children and sta

have access to safe drinking water. Although PBS has tested water in some

reopened child care centers, the testing has not been comprehensive enough

to enable PBS to fully assess potential contamination so that it can take

appropriate corrective action.

Memorandum Number A220036-2, dated August 11, 2022

The purpose of this memorandum was to identify the challenges that PBS faces

in using the $3.418 billion received under the Infrastructure Investment and

Jobs Act (IIJA), which was signed into law on November 15, 2021.

Under the IIJA, GSA received $3.418 billion for the acquisition, construction,

and repair and alteration of Land Ports of Entry. PBS faces multiple challenges

as it executes these projects, including: (1) ensuring the eective stewardship

of taxpayer funds; (2) addressing the need for qualified project managers

and contracting ocers; (3) providing eective oversight of construction

management contractors; (4) managing potential project delays and cost

overruns; (5) preparing and maintaining complete and accurate documentation;

above and strive to meet the Oce of Management and Budget’s call to ensure

the implementation of IIJA-funded projects is “ecient and eective to deliver

mitigationplan.

In April 2020, we began monitoring GSA’s activities in response to the

implementation of the Coronavirus Aid, Relief, and Economic Security Act.

During our monitoring eorts, we identified concerns with air filtration practices

in GSA-controlled (owned and leased) facilities that may lead to an increased

risk of exposure to COVID-19. As a result, we began this audit to determine

whether GSA has implemented the CDC recommendations and GSA policy to

limit exposure to COVID-19 in GSA-controlled facilities by improving central air

filtration in heating, ventilation, and air conditioning (HVAC) systems.

The CDC’s Guidance for Businesses and Employers Responding to Coronavirus

the spread of COVID-19 in the workplace. To do so, the CDC recommends

increasing ventilation and air filtration to the highest possible level without

significantly reducing design airflow. It also advises employers to check

appropriately installed.

reporting value (MERV) air filters in some GSA-owned facilities because the

aging HVAC systems cannot handle higher eciency air filters that are capable

of capturing airborne viruses. In addition, PBS has not accurately assessed

existing air filter conditions at some of its owned facilities. Further, most

operations and maintenance (O&M) contracts we reviewed do not specify a

We also found that PBS is not consistently inspecting GSA-leased facilities to

ensure that air filters meet lease requirements. In some cases, lessors used

noncompliant air filters or did not change them regularly. In addition, lessor

systems to identify deficiencies in air filtration and maximize central air

filtration in existing HVAC systems without significantly reducing design

that they clearly identify the required MERV air filters and preventive

maintenance schedules; (3) establish controls to ensure that PBS obtains

and maintains complete preventive maintenance records; and (4) ensure

that contracting ocer representatives conduct inspections of mechanical

rooms and preventive maintenance records to ensure that air filters meet

MERV requirements. For GSA-leased space, we recommended the PBS

Commissioner: (1) review and update current and future lease agreements to

ensure that they clearly identify the required MERV air filters and preventive

maintenance schedules; (2) ensure that lessors maintain and provide required

preventive maintenance records and provide timely access to mechanical

The PBS Commissioner partially agreed with our report recommendations. We

made certain revisions to one recommendation, but the revisions did not aect

our findings and conclusions.

Report Number A210018/P/T/R22004, dated April 22, 2022

Based on our findings, we made seven recommendations to the PBS

Commissioner and GSA Chief Information Ocer. The PBS Commissioner and

The purpose of this memorandum was to convey our concerns regarding

Construction Manager as Constructor (CMc) project delivery method. PBS

typically uses this delivery method for large, complex projects, such as

courthouses or major modernizations, when construction expertise is essential

during design. As of June 2022, PBS used the CMc project delivery method for

eight active capital construction projects, totaling approximately $1.2 billion.

Although PBS has taken steps to address our oce’s prior concerns with the

CMc project delivery method, we continue to observe problems with PBS’s

award and administration of CMc contracts. Of particular concern, contracting

ocers need to ensure that construction contractors appropriately accumulate

and report project costs. Additionally, contracting ocers need to avoid making

improper adjustments to the CMc contract’s guaranteed maximum price (GMP),

and ensure that the CMc contract’s GMP is not converted to a firm-fixed price

failure to mitigate these concerns will put PBS at considerable financial risk for

overpaying for construction work.

Report Number A190100/P/5/R22005, dated May 9, 2022

preventing small projects from becoming larger and more costly. We initiated

Since Fiscal Year 2015, Congress has authorized GSA to spend an average

of $346.5 million each year to fund minor repair and alteration projects. In

repair and alteration project requests submitted by PBS’s 11 regional oces.

Portfolio Management’s approval process was intended to prioritize the minor

scores projects nationwide using a common set of objective criteria.

However, we found that Portfolio Management’s review and approval process

had no discernible eect on which projects were actually performed in our

review period of Fiscal Years 2019 and 2020. Rather, Portfolio Management

approved projects based almost exclusively on project rankings submitted

by the PBS regions. Additionally, when a PBS region could not perform an

approved project, the region was able to redirect funding to other projects

without Portfolio Management’s approval.

Based on our finding, we made two recommendations to the PBS

The PBS Commissioner agreed with our report recommendations.

Report Number A210039/P/R/R22007, dated September 23, 2022

PBS National Capital Region’s (PBS NCR’s) Metropolitan Service Center

The MSC is one of five service centers in the PBS NCR that direct, manage,

and coordinate the day-to-day property management operations and programs

in GSA-controlled space. The MSC’s property management services include

on the customer’s behalf and receive reimbursement for costs plus applicable

GSAfees.

contracts are not awarded within a reasonable time frame, as required by the

agency’s RWA policy. We also found that the MSC and GSA’s Oce of the Chief

RWA Entry and Tracking Application (RETA) in a timely manner. Taken together,

these deficiencies impair the MSC’s ability to eectively manage and return

customer agency funding and increase the risk of appropriations law violations

and inaccurate financial reporting.

Based on our audit findings, we recommended that the PBS Commissioner

direct the Reimbursable Services National Program to update all applicable

policies and procedures to clarify the roles and responsibilities of PBS project

managers and OCFO budget analysts in updating RETA status for substantial

completion. We also recommended that the then Acting PBS NCR Regional

Commissioner: (1) ensure sta are trained on the RWA Policy requirements to

update RETA with a milestone schedule or written justification, (2) ensure sta

are trained on the RWA Policy to update RETA status for substantial completion,

are met for substantial completion dates to be entered into RETA.

generally agreed with our report recommendations.

We conducted a risk assessment of GSA’s charge card program to identify

and analyze risks of illegal, improper, or erroneous purchases related to GSA’s

purchase and travel cards. We based our risk assessment on limited purchase

and travel card testing.

record. In addition, the Oce of Administrative Services should ensure its

updates to their purchase card policies are made in a timely manner, and

identified no significant internal control weaknesses with the travel card

program. The risk to GSA is inherently less because the travel card accounts

charges against the travel card rather than GSA. Therefore, we assessed the

risk for GSA’s travel card program as low.

Report Number A220018/B/5/F22003, dated May 27, 2022

We performed this audit as required by the Payment Integrity Information Act of

2019. This law aims to improve eorts to identify and reduce government-wide

improper payments and requires federal agencies to review their programs

and identify those that were susceptible to significant improper payments. Our

audit objective was to determine if GSA complied with the Payment Integrity

recommendations.

We performed an implementation review to determine whether PBS has taken

the actions as outlined in the corrective action plan for our August 10, 2018,

the amount of vacant and unused leased space and whether PBS’s controls for

managing leased space are eective in preventing and reducing undue costs

in its lease portfolio; and (2) take action to ensure that existing and future

non-cancelable occupancy agreements comply with PBS policy. The PBS

corrective action to address the report recommendations and that no further

action is necessary.

Assignment Number A220062, dated September 15, 2022

Our audit found that PBS leasing sta faced obstacles in adhering to planning

milestones, increasing the likelihood that PBS will have to enter into costly

extensions or holdovers. We also found that PBS is underutilizing the Simplified

Request for Lease Proposals and missing an opportunity to reduce lease

acquisition time and prevent extensions and holdovers.

with tenant agencies and communicate the importance of compliance

Our implementation review determined that PBS has taken appropriate

Since 2001, GSA OIG has worked with the agency’s Fine Arts Program to recover for the federal government more than 700 pieces of

Photo: Fresco paintings surrounding doorway to room 5138, Department of Justice, Washington, D.C.

SIGNIFICANT INVESTIGATIONS

relating to GSA programs, operations, and personnel. The oce consists

substandard products, embezzlement, bribery, anti-trust violations, credit

card fraud, diversion of excess government property, and digital crimes.

During this reporting period, the oce opened 37investigative cases, closed

38investigative cases, referred 76 subjects for criminal prosecution, and

helped obtain 29 convictions. Civil, criminal, and other monetary recoveries

contracts valued at over $400 million. In October 2019, a federal grand jury in

Fiuza Lima with conspiracy to defraud the United States, conspiracy to commit

On August 16, 2022, John Hancock, a former program manager with a

defense contractor, pleaded guilty to wire fraud conspiracy for colluding

with Seguin, Bolduc, QuantaDyn, and Karen Paulsen, also a former program

and pay a $22.8 million forfeiture money judgment.

Seguin previously pleaded guilty to conspiracy to commit wire fraud, tax fraud,

$239,388 worth of government-owned simulator parts that he sold online.

Seguin was ordered to forfeit two vehicles and $362,515 in proceeds from

the combined sales of two real estate properties and was ordered to pay a

$2.3 million forfeiture money judgment. Seguin is scheduled to be sentenced

inOctober 2022.

Paulsen previously pleaded guilty to conspiracy to defraud the government.