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Audit of the Administration for Children and Families Awarding and Monitoring of an Unaccompanied Children Program Sole Source Contract to Deloitte Consulting, LLP

Announced on  | Last Modified on  | Project Number: A-12-22-10000
Status
Completed
Agency
Administration for Children and Families

OBJECTIVE

The Office of Refugee Resettlement (ORR), a program office of the Administration for Children and Families (ACF) within the Department of Health and Human Services (HHS), manages the Unaccompanied Children Program. In fiscal year 2021, an influx of unaccompanied children began arriving at the U.S. southern border, coinciding with the Nation's ongoing efforts to control the spread of COVID-19. As a result, ACF identified a need to increase the number of shelter beds in its provider network and entered into contracts for shelter and related services for unaccompanied children. ACF awarded a sole source contract to Deloitte Consulting LLP to provide professional support services to address the influx of children at the southern border. We will determine whether ACF awarded and monitored this sole source contract in accordance with Federal statutes, Federal regulations, and HHS policies and procedures.

TIMELINE

  • December 13, 2021
    Announced
  • February 26, 2025
    Complete

    Audit of the Administration for Children and Families Awarding and Monitoring of an Unaccompanied Children Program Sole Source Contract to Deloitte Consulting, LLP has been marked as complete. This audit resulted in 6 recommendations.

REPORT PUBLISHED

ACF Used Contractor Personnel To Perform Inherently Governmental Functions and Paid Millions in Potentially Unallowable Costs (A-12-22-10000)

25-A-12-051.01 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families update its policies and procedures for awarding contracts for other than full and open competition in emergency situations to incorporate FAR requirements for time-and-materials contracts.

25-A-12-051.02 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families provide training to program officials and contracting staff as appropriate that covers requirements for administering nonpersonal services contracts for professional support services; specifying that contracts must not be used for the performance of inherently governmental functions; providing written consent for the use of subcontractors; reviewing and approving invoices; and maintaining documentation to support costs for services performed.

25-A-12-051.03 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families update its policies and procedures for receipt and oversight of deliverables and to incorporate Federal requirements related to the: (1) review, approval, and monitoring of invoices and (2) use of CLINs to properly account for and pay contractor expenditures.

25-A-12-051.04 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families review potentially unallowable costs and obtain supporting documentation or take appropriate action to recoup from Deloitte any improperly paid amounts for $2,022,468 for invoices that did not identify CLINs to track expenses; $1,362,621 in overtime charges; $1,226,649 of labor charges for invoices that did not include specific dates when each employee performed work; $244,174 in nonlabor costs that were not supported by receipts; and $112,945 of unsupported subcontractor charges.

25-A-12-051.05 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families review and correct potential Antideficiency Act violations by deobligating and obligating funds to appropriate CLINs used and report an Antideficiency Act violation if the violation cannot be corrected.

25-A-12-051.06 to ACF - Open Unimplemented
Update expected on 09/27/2025
We recommend that the Administration for Children and Families develop and implement policies and procedures requiring contracts to include FAR clauses related to overtime requirements in contracts and for tracking and verifying that all contractor staff (including subcontractors) assigned to work on a contract complete required trainings before performing any work under the contract (or within the allowed time).

View in Recommendation Tracker
Work Plan Type
Office of Audit Services
HHS Agencies
Administration for Children and Families
Issue Areas
Contracts Emergency Preparedness and Response
Target Groups
Children and Families
Financial Groups
Other Funding