The Public Buildings Service cannot reliably show how it planned, awarded and closed out its own contracts, and the gap widened after the agency lost roughly half of its acquisition workforce. In a report issued November 6, the GSA Office of Inspector General found that all 11 PBS contract files it sampled were incomplete, that contracting officers routinely kept documents outside the agency's official system, and that sensitive pricing estimates went unmarked. The audit, numbered A250037, concludes that "PBS did not provide adequate oversight of its electronic contract files."
The stakes are not small. As of March 2026, PBS had 8,910 active contracts valued at more than $14.6 billion, covering design and construction, repair and alteration, building operations and maintenance, and disposal across the civilian federal real estate portfolio. Every one of those files is supposed to live in the Electronic Acquisition System integration, or EASi, which has been mandatory for all PBS solicitations and awards above the micro-purchase threshold since May 1, 2018.
Eleven Regions, Eleven Incomplete Contract Files
Auditors pulled a judgmental sample of one closed contract from each of PBS's 11 regions. The contracts were awarded during fiscal years 2022 and 2023, closed out in fiscal 2024, and ranged from about $1.0 million to $5.6 million. The report cites the documentation requirements in FAR 4.802 and 4.803 and PBS policy PIB 18-02, which names EASi as the official repository, and then states flatly: "However, PBS is not complying with these requirements."
The scale of the gap showed up when auditors asked for the files. PBS staff uploaded nearly 1,000 documents into the contract files in response to the audit inquiries, and in some cases could not locate the missing records at all. Measured at the time of the request, the share of documents missing ranged from 6 percent in Region 6 to 96 percent in Region 5. The Region 5 file, for a $1,288,673 contract to procure and install Physical Access Control System card readers and controllers at multiple Ohio locations, held 21 documents before the request; PBS added 528 afterward. Even then, key documents remained absent, and the region confirmed that required performance and payment bonds were never requested, which the OIG attributed to a likely oversight by a previous contracting officer.
Contracting officers told auditors that EASi itself contributes to the problem. They described the system as slow, difficult to use and limited in functionality, and said it does not support working documents, so they keep working files in Word, Acrobat and Google Drive instead.
How Losing 380 Acquisition Staff Turned Audits Into Document Hunts
The staffing picture made the missing paperwork harder to recover. According to the report, "PBS lost approximately 380 of its 774 (49 percent) acquisition personnel" during the 2025 staffing reductions, and many of those departing employees left incomplete contract files behind. That forced remaining officials to search extensively for required records.
One PBS official told the OIG that the lack of a complete file for one sampled contract forced them to go on a "fishing expedition" to obtain the required documents. Another had to work with GSA's information technology office to try to retrieve contract documents that had been stored on a former employee's external drives. The OIG notes that properly maintained files are what allow contract management to continue when acquisition staff turn over, and that this need is particularly acute after the 2025 reductions.
Who Owns the COR File? PBS Officers Could Not Agree
The audit found that 8 of the 11 contracting officer's representative (COR) files for the sampled contracts were not properly maintained. In Region 1, the COR kept no file at all, yet the closeout checklist indicated that the COR's file had been turned over to the contracting officer. CORs on four contracts, in Regions 2, 5, 7 and 8, did not consistently store their files in PBS-approved electronic systems.
Responsibility was unsettled. Only 1 of the 11 contracting officers interviewed said they were responsible for maintaining the electronic contract file and reviewing the COR tabs in EASi. Another said the COR's supervisor should handle that review, arguing that contracting officers sit in a different business line and cannot manage COR files on top of their own workload.
Why 40 of 41 Government Estimates Lacked CUI Markings
The report's third finding concerns controlled unclassified information, the category that covers proprietary pricing, trade secrets and information PBS uses to evaluate a bid or proposal. Independent government estimates (IGEs), which reveal what the government expects to pay, must carry CUI//SP-BUDG markings. Of the 41 IGEs in the sampled files, 40 lacked the required markings: 39 were not marked at all and 1 was marked incorrectly. Seven contract files, in Regions 2, 3, 4, 5, 9, 10 and 11, held acquisition plans that contained IGE amounts.
In total, the OIG counted 84 documents that were not properly marked as CUI, 79 of which were also not designated as CUI in EASi. The summary warns that contracting personnel "did not properly designate and mark CUI, increasing the risk of mishandling and unauthorized disclosure of sensitive acquisition information." Auditors also found seven documents incorrectly designated as CUI.
What the OIG Wants From the Acting PBS Commissioner
The recommendations to the Acting PBS Commissioner fall into three groups. On file management, the OIG wants PBS to enforce EASi as the official system of record, require timely uploads of all acquisition documents, ensure contracting officers use the PBS contract file checklist, and implement a standardized oversight process during administration and before closeout. It also asks PBS to work with the GSA Chief Information Officer to evaluate whether EASi's usability and document-management functions can be improved.
On COR files, contracting officers would have to verify that COR documentation is complete and transferred to the official file at closeout, document any approved alternate storage location in a memorandum for the record, and confirm that the Award Closeout Checklist reflects the actual status of the COR file transfer. On CUI, PBS would issue guidance and training on identifying, marking and designating sensitive documents. The Acting Commissioner agreed with the recommendations.
The OIG cautions that its judgmental sample "does not allow for projection of the results to the population," so the findings do not establish an error rate across all 8,910 active contracts.
What It Means for Contractors
Firms holding PBS construction, repair and facilities contracts may see closer attention to documentation at closeout as PBS works to implement the recommended oversight process before closeout. It is prudent to keep your own complete records of bonds, modifications, COR acceptances and correspondence, because the audit shows the government's copy can be incomplete or unrecoverable after staff depart. The CUI findings also matter to bidders: unmarked government estimates and acquisition plans raise the risk that pricing information circulates further than it should. With PBS agreeing to issue CUI guidance and training, solicitation documents may be marked differently going forward, though the report does not say how.
