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Treasury’s Process for Contracting for Professional Services under TARP

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Treasury’s Process for Contracting for Professional Services under the Troubled Asset Relief Program (SIGTARP-11-003), April 14, 2011

  • “Specifically, SIGTARP found weaknesses in the OFS [Office of Financial Stability] contract for legal services with Venable, as well as the OFS policies for review of Venable’s fee bills. The OFS contract for legal services did not contain sufficiently detailed requirements or instructions on how Venable should prepare fee bills or how it should describe discrete tasks within each fee bill. Moreover, once OFS received the fee bills, the OFS Contracting Officer’s Technical Representatives (“COTRs”) were given no specific standards or instructions on how to review the fee bills for accuracy and reasonableness. Venable submitted, and OFS paid without questioning, fee bills that contained block billing, vague and inadequate descriptions of work, and administrative charges not allowed under the contract. As a result, in many instances OFS could not have adequately assessed the
    reasonableness of the fees.”
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