BACKGROUND - Veterans Affairs



PERFORMANCE WORK STATEMENT (PWS)DEPARTMENT OF VETERANS AFFAIRSOffice of Internal Control (OIC)Internal Control over Reporting (ICR)Austin, TexasSupport ServicesForICR Annual Support for OMB Circular A-123, Appendix ADATE: Contents TOC \o "1-3" \h \z \u 1.0BACKGROUND PAGEREF _Toc479752022 \h 32.0APPLICABLE DOCUMENTS PAGEREF _Toc479752023 \h 33.0SCOPE OF WORK PAGEREF _Toc479752024 \h 43.1ORDER TYPE PAGEREF _Toc479752025 \h 44.0PERFORMANCE DETAILS PAGEREF _Toc479752026 \h 44.1PERFORMANCE PERIOD PAGEREF _Toc479752027 \h 44.2PLACE OF PERFORMANCE PAGEREF _Toc479752028 \h 44.3TRAVEL PAGEREF _Toc479752029 \h 54.4CONTRACT MANAGEMENT PAGEREF _Toc479752030 \h 54.5GOVERNMENT FURNISHED PROPERTY PAGEREF _Toc479752031 \h 54.6SECURITY PAGEREF _Toc479752032 \h 54.6.1POSITION SENSITIVITY PAGEREF _Toc479752033 \h 55.0SPECIFIC TASKS AND DELIVERABLES PAGEREF _Toc479752034 \h 75.1PROGRAM MANAGEMENT SUPPORT PAGEREF _Toc479752035 \h 75.1.1KICKOFF MEETING PAGEREF _Toc479752036 \h 75.1.2CONTRACTOR PROJECT MANAGEMENT PLAN PAGEREF _Toc479752037 \h 75.2ICR Planning and risk assessment PAGEREF _Toc479752038 \h 85.3documentation and test of design (TOD) PAGEREF _Toc479752039 \h 95.4Test of effectiveness (TOE) PAGEREF _Toc479752040 \h 105.5Evaluation and Reporting PAGEREF _Toc479752041 \h 125.6Remediation support PAGEREF _Toc479752042 \h 135.7TECHNICAL SUPPORT (OPTIONAL) PAGEREF _Toc479752043 \h 146.0GENERAL REQUIREMENTS PAGEREF _Toc479752044 \h 156.1PERFORMANCE METRICS PAGEREF _Toc479752045 \h 15BACKGROUNDThe Office of Internal Controls, Internal Controls over Financial Reporting (ICR) conducts department-wide reviews of internal controls over financial reporting on behalf of management to comply with OMB Circular A-123, Appendix A. ICR’s focus is on internal controls for processes and accounts that support the effectiveness and efficiency of operations, compliance with applicable laws and regulations, the integrity of the Department of Veterans Affairs (VA), and/or processes and programs that are material to the financial statements. ICR strives to identify internal control deficiencies before they affect VA financial statements. ICR also completes audit remediation, corrective action plans, and other special project efforts throughout the year. To accomplish its mission, ICR requires Contractor support to: Perform and assist in planning ICR’s assessment of internal controls over financial reporting, which are subject to an independent audit; Perform and assist in conducting test of design (TOD) over internal controls; Perform and assist in conducting test of effectiveness (TOE) over internal controls;Perform and assist in completing evaluation and reporting requirements;Develop and help implement corrective actions to resolve material weaknesses and other significant conditions identified by internal assessments, auditors, management, and others; Strengthen internal controls relating to policies, guidance, or new financial reporting and business operation initiatives, including VA’s Financial Management Business Transformation initiative; Implement improper payment provisions mandated by the Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERA) and OMB's implementing guidance; Provide project management support; Provide technical support.APPLICABLE DOCUMENTSThe Contractor shall comply with the following documents, in addition to the documents in Paragraph 2.0 in the Internal Controls Service (ICS) Basic Performance Work Statement (PWS), in the performance of this effort:OMB Circular A-123, Management's Responsibility for Internal Control, Appendix A (revised December 2004), Appendix B, Improving the Management of Government Charge Card Programs, Appendix C, Requirements for Effective Measurement and Remediation of Improper Payments, Parts I and II (revised April 2011) and Part III (revised March 2010), and Appendix D, Compliance with the Federal Financial Management Improvement Act (FFMIA);OMB Circular A-136, Financial Reporting Requirements, and the Government Accountability Office (GAO) Standards of Internal Control in the Federal Government;GAO Standards for Internal Controls in the Federal Government (the Green Book);GAO Financial Audit Manual (the Yellow Book);Treasury Financial Manual (TFM);Digital Accountability and Transparency Act of 2014 (DATA Act);Improper Payments Elimination and Recovery Improvement Act of 2012 (IPERA);American Institute of CPA’s (AICPA) Statements of Auditing Standards (SAS); SCOPE OF WORKThe purpose of this Task Order (TO) is to obtain Contractor support of financial advisory and support services to assist ICR in implementation and operation of the OMB A-123, Appendix A program for VA. The Contractor shall provide expert technical accounting and auditing advice and services at a level equivalent to an experienced and reasonable audit and accounting professional standards. The Contractor must also conduct risk assessments, develop documentation, perform tests of design and operating effectiveness, evaluate control deficiencies, conduct research and provide sound financial advice on complex financial transactions that comprise financial statement line items, and assist in remediation of material weaknesses, significant deficiencies, and control deficiencies. The Contractor shall provide support for data analytics, statistical services, and actuarial services support. ORDER TYPEThis TO shall be performed on a Firm-Fixed Price (FFP) basis. PERFORMANCE DETAILSPERFORMANCE PERIODThe period of performance for this TO is 12 months, with three 12-month option periods, if exercised.PLACE OF PERFORMANCETasks under this PWS shall be performed at the Contractor site, as well as various VA facilities (see 4.3 travel section for details). TRAVEL The Government anticipates travel under this effort to perform the tasks associated with the effort, as well as to attend program-related meetings or conferences throughout the period of performance. The total estimated number of trips in support of this effort is 50 trips. Potential locations include all VA facilities and locations. CONTRACT MANAGEMENTAll requirements of Sections 7.0 and 8.0 of the Basic PWS apply to this effort. This TO shall be addressed in the Contractor’s Progress, Status, and Management Report as set forth in the Basic ERNMENT FURNISHED PROPERTYNone.SECURITYAll requirements in Section 6.0 of the Basic PWS apply to this effort.POSITION SENSITIVITYPosition SensitivityBackground Investigation (in accordance with Department of Veterans Affairs 0710 Handbook, “Personnel Security Suitability Program,” Appendix A)LowNational Agency Check with Written Inquiries (NACI) A NACI is conducted by OPM and covers a 5-year period. It consists of a review of records contained in the OPM Security Investigations Index (SII) and the DOD Defense Central Investigations Index (DCII), FBI name check, FBI fingerprint check, and written inquiries to previous employers and references listed on the application for employment. In VA it is used for Non-sensitive or Low Risk positions.ModerateModerate Background Investigation (MBI) A MBI is conducted by OPM and covers a 5-year period. It consists of a review of National Agency Check (NAC) records [OPM Security Investigations Index (SII), DOD Defense Central Investigations Index (DCII), FBI name check, and a FBI fingerprint check], a credit report covering a period of five years, written inquiries to previous employers and references listed on the application for employment; an interview with the subject, law enforcement check; and a verification of the educational degree.High Background Investigation (BI) A BI is conducted by OPM and covers a 10-year period. It consists of a review of National Agency Check (NAC) records [OPM Security Investigations Index (SII), DOD Defense Central Investigations Index (DCII), FBI name check, and a FBI fingerprint check report], a credit report covering a period of 10 years, written inquiries to previous employers and references listed on the application for employment; an interview with the subject, spouse, neighbors, supervisor, co-workers; court records, law enforcement check, and a verification of the educational degree.The position sensitivity and the level of background investigation commensurate with the required level of access for the following tasks within the PWS are as follows:Position Sensitivity and Background Investigation RequirementsTask NumberLow/NACIModerate/MBIHigh/BI5.1.1 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.1.2 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.2 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.3 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.4 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.5 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.6 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX 5.7 FORMCHECKBOX FORMCHECKBOX FORMCHECKBOX The PWS tasks identified above and the resulting Position Sensitivity and Background Investigation requirements identify, in effect, the Background Investigation requirements for Contractor individuals, based upon the tasks the particular Contractor individual will be working. The submitted staffing plan must indicate the required Background Investigation Level for each Contractor individual based upon the tasks the Contractor individual will be working, in accordance with their submitted proposal.Contractor individuals will also be required to request and maintain network access via CITRIX Access Gateway (CAG) for remote connectivity for the duration of the TO.SPECIFIC TASKS AND DELIVERABLESAll deliverables shall be written in the active voice, direct style and at the twelfth-grade comprehension level, as measured by the Flesch-Kincaid readability index. ICR will provide templates in MS Excel and MS Word formats for the Contractors use upon award of the task order.PROGRAM MANAGEMENT SUPPORTICR estimates work under this task will require 1.5 full time contractors in the Partner, Manager and Consultant labor categories.KICKOFF MEETINGThe Contractor shall hold a kickoff meeting within 10 days after award (virtual meeting is acceptable). The Contractor shall present, for review and approval by the Government, the details of the intended approach, work plan, and project schedule to complete all tasks defined in this PWS. The Contractor shall provide a meeting agenda at least five days prior to the meeting and meeting minutes shall be provided to all attendees within three days after conclusion of the meeting. The Contractor shall invite the CO, Contract Specialist, COR, and any other necessary VA personnel.Deliverables: Meeting Agenda Meeting MinutesCONTRACTOR PROJECT MANAGEMENT PLANThe Contractor shall deliver a Project Management Plan (PMP) within 10 days after the kick-off meeting that lays out the Contractor’s approach, timeline, and tools used in execution of this TO. Key topics that shall be included in the PMP are:Staffing planKey tasks and sub-tasksDeliverables Key milestones with an associated time-phased scheduleThe Government will provide comments within 10 days after the PMP submission. The Contractor shall make adjustments based on the Government’s comments and submit the final PMP within seven days after receiving the Government’s comments. The Contractor shall provide formal PMP updates as part of the monthly status reports, as required in the Base PWS, for each month no later than the close of business (5:00 PM Central Time) on the fifth day of the next month. The Contractor shall make informal PMP status reports on a weekly basis and provide them to the COR or designated representative by telephone or e-mail.Deliverables: Contractor PMPICR Planning and risk assessmentThe Contractor shall provide support to shift VA’s A-123, Appendix A program from a cyclical assessment approach to a risk-based, continuous monitoring approach. The Contactor will support ICR in planning for internal control assessments over significant processes based on quantitative, material contributions to VA’s financial statements and qualitative factors. The Contractor shall provide this support through performing a comprehensive risk assessment (ICR and IPERA), supporting ICR in planning for current fiscal year test of design (TOD) and test of effectiveness (TOE) activities, and conducting various financial statement analyses. ICR estimates work under this task will require 3.5 full time contractors in the Manager, Sr. Consultant/Auditor, Consultant/Auditor, and SME/Statistician labor categories. The Contractor shall conduct and prepare a detailed ICR risk assessment. The risk assessment shall include analysis of risk across VA reporting entities (Administrations) and Accessible Units. The Contractor, at a minimum, shall perform the following during the risk assessment:Review the VA financial statements (balance sheets, statements of net cost, statements of change in net position and statements of budgetary resources) published in the annual financial report; calculate planning, design, and test materiality; analyze significant financial statement line items and United States Standard General Ledger (USSGL) accounts; and determine their relation to VA’s business processes, sub-processes, and internal controls. For all identified significant financial statement line items, USSGL accounts, business processes and sub-processes, assess the risk for potential misstatement based on both qualitative and quantitative factors. Quantitative factors include but are not limited to materiality and significant account fluctuations. Qualitative factors include but are not limited to existing weaknesses, compliance risk, complexity of process, significant fluctuations in account balance, decentralization of process, fraud risk, and human capital risk. Both quantitative and qualitative factors shall be supported by in-depth analysis of each factor. Recommend categorization of business processes and sub-processes as high, medium, or low risk.Perform an in-depth risk analysis to determine the most material Accessible Units contributing to the relevant business process and sub-process general ledger accounts.The Contractor shall review the results of the comprehensive risk assessment and ICR’s current business process narratives, and provide a recommended TOD and TOE testing schedule in the workbook that identifies the process, program and location for testing. The Contractor shall deliver the first draft of the risk assessment workbook no later than December 8, 2018. ICR will have 5 days to review the draft deliverables and provide comments to the Contractor. The Contractor shall have 5 days to revise the draft and submit it to ICR.The Contractor shall also provide support to complete status of internal controls over improper payments table and narrative to be included in the Annual Financial Report (AFR). The type of support shall, at a minimum, include:Preparing an internal controls questionnaire for programs to complete;Preparing briefing materials for bi-monthly IPERA Governing Board meetings;Evaluating the supporting documentation and scoring program areas on the five internal control components;Conducting and participating in discussions with the programs on their scoring results;Completing the table and narrative to be included in the AFR.The Contractor shall deliver the first draft of the IPERA table and narrative no later than May 20, 2018. ICR will have 10 days to review the draft deliverables and provide comments to the Contractor. The Contractor shall have 10 days to revise the draft and submit it to ICR.The Contractor shall also provide support in developing an ICR internal controls maturity model scorecard. The Contractor will recommend specific TOD and TOE assessment results criteria and a rating system to assess the maturity of internal controls across VA’s Accessible Units. Deliverables: Comprehensive Risk Assessment WorkbookIPERA Table and Narrative for AFRICR Internal Controls Maturity Scorecard Methodologydocumentation and test of design (TOD)The Contractor shall support the documentation phase of the internal controls assessment lifecycle by supporting the performance of TOD over significant VA business processes. This support includes assisting ICR perform the following internal control assessment activities: detailed baseline walkthroughs of business processes, stakeholder interviews, test of one through inquiry, observation, examination, and re-performance of artifacts and key documents, and preparing business process narratives and associated risk control matrices. Business process narratives will also include flow charts and discuss linkage to the Treasury Financial Manual - USSGL and financial impact. The Contractor shall assess the design of the identified controls and recommend internal controls as gaps, key, or non-key. The Contractor shall perform actuarial services as necessary to validate and verify actuarial estimates for future liabilities and VA Benefits Administration (VBA) programs (Compensation, Burial, Education, etc.) during TOD as required.ICR estimates work under this task will require 5.5 full time contractors in the Sr. Consultant/Auditor, Consultant/Auditor, Subject Matter Expert/Actuary, and Tech Writer labor categories.ICR is responsible for coordinating the overall site visit with designated coordinators for the major program areas during documentation and TOD. Coordination includes setting up the entrance conference, exit conference, negotiating work hours, arranging for workspace, and providing information required to gain site access. Process narratives and flowcharts will describe, at a minimum, the following controls and processes per the GAO/PCIE Financial Audit Manual:? Detailed narrative for each processes’ cycle transactions in the requested area, significant accounting applications, applicable financial management systems, roles and responsibilities of key stakeholders in the process, document and address key controls and financial events that occur, interfaces with other business cycles, significant policies and procedures, Standard General Ledger accounts, reconciliations, and any other relevant information.? Detailed flowcharts for each area’s narrative that should include input and output report documents, processing steps, forms and files used, business units involved, and interfaces with other cycles and IT systems.? Identify and number key financial and system controls throughout the process narratives per an ICR- provided naming convention.Identify control risks that relate to the identified controls and include in the risk control matrix cross-referencing the risk to the control number.Identify test steps and documents required to evaluate control design to verify that they support control objectives and assertions as intended. Test steps will be documented for both key and non-key controls.ICR anticipates up to ten process narratives for documentation and test of design.Subject areas will be determined after completion of planning and risk assessment but will focus on VA’s significant business processes.Deliverables:Business Process Narratives Risk and Control MatricesTest of effectiveness (TOE)The Contractor shall assist in conducting Appendix A internal control test of effectiveness throughout the VA. This support includes evaluating the operational effectiveness of key controls deemed to be designed effectively, corresponding information-processing objectives, and related financial statement assertions. ICR will provide the Contractor with all relevant test plans, test worksheets and test materials. Additionally, the Contractor shall perform statistical services as necessary to develop appropriate universe size, sample size and stratification of data to support ICR internal control testing.ICR estimates work under this task will require nine full time contractors in the Sr. Consultant/Auditor and Consultant/Auditor labor categories on the testing teams. Testing teams shall utilize the same individuals to the maximum extent possible throughout the test period for continuity, familiarity with test procedures, process narratives, and internal control knowledge. ICR will provide the Contractor a preliminary list of the sites selected for testing no later than October 14, 2018. TOE Testing will start on or about November 15, 2018. The following chart provides a potential list of the category of facilities that be tested. This list is not considered comprehensive. Abbreviations used below are: VA Medical Centers (Hospitals) (VAMC), VA Regional Offices (Compensation & Pension) (RO), VA Education Regional Processing Offices (RPO), VA Debt Management Center (DMC), VBA Finance Center (VBAFC), VA Central Office located in Washington, DC (VACO), VA Consolidated Patient Accounting Centers (CPACs), VA Consolidated Mail Outpatient Pharmacy (CMOP), Financial Services/Consolidated Centers (FSC), and Administrative and Loan Accounting Center (ALAC).VAMC (1 mock site)VAMCs (12 sites)RO (1 mock site)ROs (4 sites)CPACs (2 sites)CMOPs (2 sites)VACO (1 site)FSCs (3 sites)ALAC (1 site)DMC (1 site)RPO (1 site)VBAFC (1 site)The above locations are tentative sites and should not be considered a comprehensive list. ICR will provide the Contractor a final list of the sites selected for testing no later than completion of paragraph 5.2. Site visits will not be scheduled during weeks where Federal holidays are observed.ICR is responsible for coordinating the overall site test list with designated coordinators for the major program areas. Coordination includes setting up the entrance conference, exit conference, negotiating work hours, arranging for workspace, and providing information required to gain site access.The Contractor shall:Become familiar with ICR testing methodologies and procedures;Assist in updating evidence request lists and acquiring samples ;Attend all briefings to include introductory calls, entrance and exit briefings during the testing period; Be prepared to brief test results for areas assigned to them;Prepare test worksheets and PowerPoint presentations for each site visit that describe audit findings with sufficient detail for the audited site to verify the exceptions and take corrective action. Test worksheets shall be cross-referenced to their underlying audit work papers;Provide ICR write-ups on any significant deficiencies that need to be brought to management’s attention immediately;Test worksheets and associated work papers and reports shall be delivered to ICR within seven days of completing a site visit;Assist in developing the Findings and Recommendations tables.ICR will provide testing training to the Contractor via VTC or in person prior to the start of testing. Location of testing training will be determined upon completion of planning in paragraph 5.2. Audit work papers shall adhere to AICPA standards and enable an experienced financial auditor, having no previous connection to the testing, to understand the nature, timing, extent, and results of audit procedures; the audit evidence obtained and its source; and the conclusions reached, including evidence that supports the auditors' significant judgments and conclusions. Additionally, work papers shall:Contains all elements of an audit finding; i.e., condition, cause, effect, criteria, and recommendations;Identify the preparer and the working paper's purpose and conclusions;Have appropriate supervisory sign-offs;Use summary work papers;Be appropriately cross-referenced to each other, summary documents, VA Audit Alerts, and the audit reports.The Contractor shall submit Testing Documentation to ICR seven days after departure from each test site. Deliverables: Testing Documentation (Test Worksheets and associated audit work papers)Evaluation and ReportingThe Contractor shall assist and provide support in the evaluation, assessment, classification, and aggregation of internal control deficiencies identified during the testing process. This work involves determining the significance of each deficiency by assessing the magnitude and likelihood of resulting potential misstatements. Based on the assessment, a deficiency or group of deficiencies are classified as material weaknesses, significant deficiencies, or control deficiencies. ICR estimates work under this task will require two full time contractors in the Senior Consultant/Auditor labor category.The Contractor shall provide evaluation and reporting support as follows:Develop a comprehensive Summary of Aggregated Deficiencies Framework to support the categorization of identified internal control deficiencies;Review TOD testing documentation and develop deficiency recommendations based on findings during TOD;Review TOE testing documentation and develop recommendations based on findings during TOE;Analyze findings and communicate with VA stakeholders, as needed, to identify root causes and possible corrective actions;Assist with preparation of the ICR Findings and Recommendations (F&R) report, the VA Statement of Assurance (SOA) and Agency Financial Report (AFR), as needed;Manage a VA hosted SharePoint site to summarize ICR internal controls documentation, testing, reporting, remediation and other information pertaining to OMB A-123, Appendix A activities across the VA.Deliverables:Findings and Recommendation Report Root Cause Analysis ReportSharePoint Site Administration Remediation supportThe Contractor shall assist and provide support to ICR in the development of corrective action plans (CAP) and remediating areas identified during audits or other testing (internal and/or external) as material weaknesses, significant deficiencies, control deficiencies or any other area deemed necessary by the Government. ICR anticipates up to 15 CAPs per year based on historical data. ICR estimates work under this task will require one full time contractor in Consultant labor categories.The Contractor shall collaborate with VA stakeholders as necessary to develop corrective action plans that resolve material weaknesses, significant deficiencies, and control deficiencies as identified by internal assessments, auditors, management, and other entities. The Contractor shall coordinate with VA Financial Process Improvement and Audit Readiness (FPIAR) personnel to determine redundancy or duplication of effort and to combine CAP efforts from other audits and reviews, if available.After coordination with FPIAR, the Contractor shall assist VA process owners during execution of all tasks contained in the designated CAPs by employing the following methodology:Coordinating remediation approach with the process owners and gaining their buy-in;Scheduling and hosting In-Process Reviews (IPRs)on a monthly basis;Developing and distributing IPR and other meeting agendas, minutes, and action logs;Maintaining configuration control of a CAPs SharePoint site;Coordinating real-time findings from ICR testing with process owners on a continuous basis from other audits and other findings from previous years that are still open and active; Conducting frequent (quarterly or monthly) face to face, telephonic, and email communication with VA process owners – which is essential to successful CAP execution; Providing ICR with a monthly report summarizing Contractor remediation assistance activities throughout the month.Deliverables:Corrective Action Plans (CAP)Monthly CAP Status reports TECHNICAL SUPPORT (OPTIONAL)The Contractor shall provide support and assistance related to financial statement auditing, data analytics, actuarial services and statistical support services. These services are ad hoc in nature and may be utilized based on requirements at the time support is required by ICR and/or VA management. Upon identification of a requirement, ICR will notify the contracting officer of the scope and requirement. If utilized, ICR estimates work under this task will require three full time contractors in the Sr. Consultant, Consultant and Subject Matter Expert (SME) labor categories.Technical and financial statement auditing support shall include:1.Providing subject matter expertise on internal controls and financial statement areas pertaining to VA’s external audit. This may include collaboration with VA stakeholders and external auditors to address audit findings and external auditor requests;2.Analysis of VA balance sheets, statements of net cost, statements of change in net position and statements of budgetary resources and their relation to internal controls and assessing risk in VA programs and activities;3.Assisting ICR as necessary with ongoing financial statement audits, to include GAO and IG audits;4.Performing data analysis and data mining to support ICR as necessary;Deliverables:To Be Determined based upon emerging requirement.GENERAL REQUIREMENTSPERFORMANCE METRICSThe table below defines the Performance Metrics associated with this effort:Performance ObjectivePerformance StandardAcceptable Performance LevelsTechnical NeedsShows understanding of requirementsEfficient and effective in meeting requirements Meets technical needs and mission requirementsOffers quality services/productsSatisfactory or higherProject Milestones and ScheduleQuick response capabilityProducts completed, reviewed, delivered in timely mannerNotifies customer in advance of potential problemsSatisfactory or higher3. Project StaffingCurrency of expertisePersonnel possess necessary knowledge, skills and abilities to perform tasksSatisfactory or higher4. Value AddedProvided valuable service to GovernmentServices/products delivered were of desired qualitySatisfactory or higherThe Government will utilize a Quality Assurance Surveillance Plan (QASP) throughout the life of the contract to ensure that the Contractor is performing the services required by this PWS in an acceptable manner. The Government reserves the right to alter or change the QASP at its own discretion. A Performance Based Service Assessment Survey will be used in combination with the QASP to assist the Government in determining acceptable performance levels. The COR will determine if the performance of the Contractor is below a metric standard and deem it unacceptable. The COR will then notify the CO. ................
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