Most of the managers for the contracts we reviewed asserted that when they approved invoices, they reviewed narratives summarizing the work performed. However, these narratives are generated by the contractors and do not serve to independently verify that the contractors have, in fact, performed the work to the standards of the contracts. In establishing its 2017 policies, the Authority acknowledged the limitations of this invoice review process by creating a parallel but distinct process through which it requires contract managers to identify, document, track, receive, review, and accept contract deliverables.
| The Authority's policies and procedures clearly state that this process-known as deliverables management-is meant to ensure the Authority is able to construct the high-speed rail system on schedule and within budget. The text box describes the Authority's procedural requirements for managing deliverables and identifies the documentation required to track that process. The fundamental purpose of these tracking activities is ensuring that the contractors' deliverables are consistent with quality, timeliness, and cost requirements. Despite the specificity of the Authority's requirements related to deliverables, the contract managers we reviewed did not comply with the required actions. None of the contract managers for the nine contracts we reviewed used the standardized deliverables tracking log-or any other document-to independently track the status and review of contract deliverables. Further, contract managers did not document their formal reviews of deliverables; instead, they described various alternative methods for these reviews. Some contract managers claimed to monitor contracted work simply by observing and working closely with contracted staff on a daily basis. Others relied on the RDP consultants to approve contractor-generated progress reports and individual deliverables, after which the contract managers would approve payment. Still others stated they relied on other Authority staff and subject matter experts to evaluate and approve individual deliverables, although those delegated evaluations were also generally not documented. Though we recognize that subject matter experts play an important role in assessing the quality of work, their expertise does not supplant the responsibilities of the contract managers. |
Finally, instead of using the Authority's required templates for tracking the receipt and sufficiency of deliverables, contract managers for four of the nine contracts we reviewed provided documents that they use to verify the extent to which deliverables were timely and adequately completed. However, we noted that the contractors prepared these documents. In fact, for nearly all the contracts we reviewed, the only documented source of information regarding the timeliness and status of deliverables came from the contractors themselves. As a result, we were generally unable to determine how the Authority independently ensured it received the deliverables for which it paid and that they were of the quality that it required.