PBS Should Improve Its Oversight of Electronic Contract Files

Why We Performed This Audit

GSA’s Public Buildings Service (PBS) acts as the landlord for the civilian federal government, managing more than 8,600 owned and leased assets with over 370 million rentable square feet of space. To fulfill its responsibilities, PBS awards contracts for an extensive range of real property management services, including design and construction; repair, alteration, and renovation; building operations and maintenance; and disposal. As of March 2026, PBS had 8,910 active contracts valued at more than $14.6 billion.

Contract files serve as the official record of acquisition decisions and help ensure proper oversight and administration of contracts. These files document how contracts were planned, awarded, administered, and closed out, which helps ensure transparency, accountability, and compliance with federal acquisition requirements. Accordingly, contract files must be complete, accurate, and reliable. Properly maintained contract files are also critical to ensure continuous, effective contract management in cases of acquisition staffing turnover. In addition, contract files often contain sensitive information that, while not classified, still requires some level of protection against mishandling and unauthorized access. This information is referred to as controlled unclassified information (CUI). Among other things, acquisition-related CUI includes proprietary pricing information, financial information, trade secrets, and information used by PBS to evaluate a bid or proposal and enter into a contractual agreement.

PBS uses the Electronic Acquisition System integration (EASi) as its official repository for electronic contract files. EASi standardizes contract documentation and provides a centralized record of contractual actions throughout the acquisition life cycle. Since May 1, 2018, EASi has been mandatory for all PBS solicitations and awards above the micro-purchase threshold.

Because of the importance of contract files, we included this audit in the GSA Office of Inspector General’s Fiscal Year 2025 Audit Plan. Our audit objectives were to determine whether PBS maintains adequate oversight to ensure that: (1) contract files are complete, accurate, and properly maintained within EASi; and (2) documentation that contains CUI is properly marked and designated in EASi in accordance with the Federal Acquisition Regulation (FAR), General Services Administration Acquisition Manual (GSAM), and PBS policy.

What We Found

PBS did not provide adequate oversight of its electronic contract files. We found that PBS contracting personnel are not maintaining required documentation within EASi, PBS’s official system of record, and as a result, PBS’s electronic contract files are not complete. Further, documentation necessary for effective contract administration and oversight was also incomplete or missing from the electronic contract files. Lastly, we found that contracting personnel did not properly designate and mark CUI, increasing the risk of mishandling and unauthorized disclosure of sensitive acquisition information.

What We Recommend

1. Strengthen PBS contract file management by:
   1. Enforcing the requirement that PBS contracting officers use EASi as the official system of record.
   2. Requiring PBS contracting officers to upload all acquisition documents to EASi in a timely manner.
   3. Ensuring contracting officers use the PBS contract file checklist to verify completeness and accuracy of all contract files.
   4. Implementing a standardized oversight process during contract administration and prior to closeout to ensure contract files are complete, accurate, and compliant with FAR, GSAM, and PBS policy requirements.
   5. Providing training or refresher guidance to PBS contracting personnel on proper contract file documentation, effective use of EASi, and the importance of maintaining timely and complete acquisition documents.
2. In conjunction with the GSA Chief Information Officer, evaluate EASi to determine whether its usability and document‑management functionality can be improved.
3. Strengthen oversight of contract documentation maintained by contracting officers’ representatives (CORs) by:
   1. Requiring contracting officers to verify that all contract documentation maintained by CORs is complete and properly transferred to the official contract file at closeout.
   2. If any portion of the COR file is stored elsewhere, ensuring that the contracting officers include a memorandum for the record in the contract file identifying the approved alternate storage location.   
   3. Ensuring that contracting officers confirm that the Award Closeout Checklist accurately reflects the status of the COR file transfer.
4. Issue guidance, and provide associated training, to PBS contracting personnel on the proper identification, marking, designation, and management of CUI. This should include:
   1. Instruction on correctly identifying CUI, applying required CUI banners, and checking the CUI designation checkbox in EASi.
   2. Guidance specifying which acquisition documents must be marked as CUI.
   3. Clarification of the roles and responsibilities of acquisition personnel to ensure consistent and compliant CUI handling during contract administration and through contract closeout.

The PBS Acting Commissioner stated that PBS agrees with the report recommendations. His written comments are included in their entirety in Appendix C.