The USDA OIG conducted an inspection/evaluation of Forest Service pre-award contracting activities under the Infrastructure Investment and Jobs Act (IIJA) and found that the agency failed to comply with Federal laws and regulations in executing the pre-award contracting process for 13 sampled contracts. The total questioned costs amount to $48,255,403 in unsupported costs for the period November 15, 2021 through March 31, 2025. The OIG issued two open recommendations: (1) to evaluate pre-award documents for the 13 contracts with missing documentation and document conclusions, and (2) to establish and implement oversight controls to ensure contract file documentation is complete and fully compliant.

Agencies receiving Federal funds for construction or contracting activities should review their pre-award documentation practices to ensure compliance with Federal procurement requirements. While the OIG report itself does not impose immediate penalties, questioned costs of $48.2 million are subject to disallowance by the awarding agency. Contracting officers and program managers should verify that all required pre-award documentation is complete, properly executed, and retained in contract files before award. Enhanced oversight controls for documentation completeness should be implemented as a priority.