profiles, working papers, and state banking performance Each quarter, the FDIC provides a contract-specific report to the Board of Directors for complex contracts over $5 million and for all contracts over $20 million. stability and public confidence in the nations financial Industry Standard. This text file was formatted by the FDIC OIG to be accessible to users with visual impairments. This requirement will be a private invitation for bid and will result in a single-award Basic Ordering Agreement ("BOA"). Since the FDIC relied on Blue Canopy to provide human capital (staffing) in key areas of information security and privacy, the FDIC needed to supervise and manage how Blue Canopy would continue to provide its services in the event that Blue Canopys human capital was impaired or negatively impacted by significant events. In fact, Blue Canopy services represented nearly 40 percent of the FDICs annual operating expenses for Information Security ($42.3 million), and the FDIC did not have a sufficient process to identify these Critical Functions and implement heightened monitoring. . Further, the official stated that Blue Canopy complied with the FDICs directives governing access to and operations at FDIC offices and facilities. In addition, NASA considered internal capability when procuring a Critical Function, and CFPB ensured that Contract Officers had appropriate backgrounds, such as Information Technology expertise for procured Information Technology services. Additionally, the FDIC needed to routinely test, or review the test results of, those plans to ensure continuity of service. )% oYki|Wl{)9hg3(EV{Ih`f=aegasg`c$.hY+ R#@P-0to 1P$C@"WWG5mMsW>ne7#dMyrhkJY-~&tMWkZQG--+d7_#VZ {++Ojb~S+yKoBm#%G8@5p>Wwl)Ng=H]5~,SP"q,1sM/e,1@ vD2Hf3u,2G}H7[]f#[x2 In particular, an over-reliance assessment should be performed regularly, on an independent basis, to validate the agencys compliance with and the effectiveness of established controls. prqCG} CD0L@A. Source: OIG analysis of the FDIC Acquisition Policy Manual (August 2008) and the Acquisition Procedures, Guidance and Information (January 2020). Recommendation 1: Incorporate the provisions of OMB Policy Letter 11-01 guidance into the FDIC Acquisition Policy Manual (August 2008) and Acquisition Procedures, Guidance and Information document (January 2020). 1.405(b). An official website of the United States government. As a result, the GAO recommended that DHS should (1) develop a risk-based approach for reviewing service requirements to ensure proposed service requirements are clearly defined and reviewed before planning how they are to be procured; (2) update the Inherently Governmental and Critical Functions Analysis to provide guidance for analyzing, documenting, and updating the federal workforce needed to perform or oversee service contracts requiring heightened management attention; and (3) [develop] guidance identifying oversight tasks or safeguards personnel can perform, when needed, to mitigate the risk associated with contracts containing closely associated with inherently governmental functions, special interest functions, or critical functions..
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