Review of VA High-Dollar Consulting Contracts

The Department of Veterans Affairs (VA) obligated over $1.2B on consulting and professional services contracts in FY2024. Under the Federal Acquisition Regulation (FAR) and the Competition in Contracting Act (CICA), agencies must justify sole-source awards and document that contract pricing is fair and reasonable. Our review of a sample of 40 contracts above $5M found that 12 lacked a current, signed Determination and Findings (D&F) for other than full and open competition, and 8 had no documented price reasonableness determination in the contract file. VA’s own policy (VAAR and internal directives) requires that all high-dollar consulting engagements be tied to a documented mission need and that the contracting officer maintain a complete audit trail. This advisory does not conclude that the contracts were improper, but it does conclude that the documentation is insufficient to demonstrate compliance. We recommend that the VA Office of Acquisition, Logistics, and Construction conduct a file review and that the OIG consider a procurement audit focused on consulting services.