The Government Accountability Office (“GAO”) has called for increased oversight of contractors supporting the Troubled Asset Relief Program (“TARP”).[1] The GAO’s call for increased oversight of contractors stems from its concerns about the types of contracts awarded by the Department of Treasury and the lack of clear mitigation plans for potential and actual conflicts of interest.

Since TARP was authorized by the Emergency Economic Stabilization Act (“EESA”), Treasury has awarded a variety of contracts for legal, investment consulting, accounting, and other services using expedited procedures under the Federal Acquisition Regulation (“FAR”). As of November 25, 2008, Treasury had awarded two indefinite delivery-indefinite quantity (“ID/IQ”) contracts using other than full and open competition and five blanket purchase agreements or orders against existing federal supply schedules maintained by the General Services Administration (“GSA”).[2] Both arrangements provide Treasury with the flexibility to order work as needed. These contracts and agreements offer awards that range in value from $5,000 to $2.5 million and in length from six months to several years.

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