If the recent U.S. Government Accountability Office (GAO) report, Human Trafficking: Agencies Need to Adopt a Systematic Approach to Manage Risks in Contracts, GAO-24-106973, Jul 30, 2024, looks familiar, it is because the issue of trafficking in federal contracting has long existed and has yet to be satisfactorily addressed. This latest report found that the Departments of Homeland Security (DHS), Defense (DOD), State and the U.S. Agency for International Development (USAID) have not taken a systematic approach to managing trafficking risks in contracting. This approach would include identifying and analyzing, developing responses to, and communicating the risks to contracting officials. Such an approach would better position agencies to support the U.S. policy of zero-tolerance for human trafficking.
In 2021, the GAO found that selected DOD components conducted limited oversight of contractors, did not meet combating trafficking in persons (CTIP) training requirements for contracts, and did not report all TIP violations and investigations in contracts in annual self-assessments (GAO-21-546). In 2019, the Office of Management and Budget (OMB) memorandum, Anti-Trafficking Risk Management Best Practices & Mitigation Considerations, M-20-01, provided Federal acquisition guidance to review contract spending and ensure necessary safeguards and reviews are in place for high-risk areas. The below figure breaks out the general risk management steps agencies should take, as well as specific steps and roles parties play in the acquisition lifecycle.
Anti-Trafficking Roles and Responsibilities
The GAO findings were not all negative and acknowledged departments’ initial steps to identify trafficking risks in their contract spending (except USAID). The four agencies concurred with the recommendations so hopefully this issue will eventually be put to rest.
