ARP-supported student researchers have developed a tool that allows agencies to pinpoint the agencies, firms, and markets that are most at risk of human trafficking based on type of market, location of market, dollars and actions completed and State Department intelligence.
The student team of Air Force Contracting Officers recently completed the MBA program's curriculum on Acquisition and Contract Management within the Department of Defense Management.
Captain Willis Crouch shared the motivation he and his teammates, 1Lt Kevin Peaslee and 1Lt LaDon Morris, had for conducting this research:
We are all contracting officers and after finding out there was human trafficking on DoD contracts, we didn’t want to go back to our career field without having done something about it. Through awarding contracts that end up having human trafficking (whether known or unknown) the contracting officer is indirectly responsible.
For the past year, Crouch, Peaslee, and Morris have worked with the DoD Combatting Trafficking in Persons Program Management Office (CTIP PMO) to prevent, monitor and respond to human trafficking risk in defense acquisition using federal spending data.
These students did a robust analysis of human trafficking prevention, monitoring and response methods considering DoD spending as potential signals. They worked with a team at Air Force Installation Contracting Center (AFICC) at Wright-Paterson Air Force Base to build a prototype of their idea.
In December, the project team briefed the Department of State Senior Policy Operating Group (SPOG) on their research and findings related to human trafficking risk prevention, monitoring and response in DoD markets.
Here’s some of the feedback they got from that presentation:
“Everyone [on the SPOG] loved the dashboard, the charts, and the recommendations. Your work is helping DoD - and all the USG agencies - make a quantum leap in the way we prevent trafficking in government contracting. [Name] and I noticed DoD components that have been reluctant to engage beginning to turn around. And you heard [OMB] - you elicited the most interaction on a presentation ever in this committee. Thank you so much for all your great work.”
“We’ve just tasked our agency reps with some data searching and hope to develop a list of PSCs of concern next year. Taking that info, and perhaps others like the Responsible Sourcing Tool’s countries of concern lists and DOL’s force labor data, and allowing filtering on those fronts would likely yield a more immediately actionable pull. …I’m very interested in keeping the tool going and building upon it!”
DoD still struggles to meet the policy of “zero-tolerance” put into place by the National Security Presidential Directive (NSPD)-22 in 2002 – despite a National Action Plan to Combat Human Trafficking, a DoD Instruction, a designated program office, and federal acquisition policy all condemning the use of forced labor by USG contractors.
Captain Crouch gave us some extra insight into the team's thinking as they created this operational tool.
We understand the relationship between contracting, the contractor, the contracting officer representative, and the Federal Acquisition Regulation. Using that knowledge, we wanted to explore areas that were practical and real-world applicable. We envisioned ourselves at our previous or next duty assignment and tried to think about what something would look like that could actually be used to help identify where human trafficking is happening on contracts, and what can be done to better prevent, monitor, and respond to it.
During our spend analysis class, we learned how to rationalize data. We were able to play with Air Force Business Intelligence Tool (AFBIT) lite which has a global map that identifies amounts of spend, what the spend was by Product Service Code (PSC) and from what agency. So we started to envision that sort of set up, plus being able to quickly visualize how that spend correlated with the Department of State’s Tier System. We used an AFBIT lite map and masked it over a Tier Map in PowerPoint to develop a rough minimum viable product that identified the amount spend by country AND what the country’s rating was. What AFICC/KA did with that was lightyears ahead of what we could have imagined.
In our first introduction to the SPOG, there were many agencies asking for a way to quickly identify their spend profiles. Our second presentation gave them our research question, our sponsor, how and why we did a spend analysis, and then our recommendations. The tool was presented last, and it seems that it captured a lot of interest—so much that the SPOG sent it out to the agencies to use in answering a tasker for all Federal CTIP Offices.
There are too many to list, and some findings may not find favor with leadership. It’s a horrible thing that is happening (human trafficking), and even more so that it is happening on US contracts. Saying zero-tolerance and actually having no tolerance cannot be separated. We discovered that in some cases the US appears to have a conditional zero-tolerance against human trafficking and we hope that our research and the work of the SPOG, DOD CTIP PMO and everyone else involved would be heard.
The recommendations are meant to be applied to areas/agencies that are identified as high risk due to their purchasing of at-risk PSCs or in poorly rated countries (Tier 3, Tier 2 Watch List). The tool can easily identify those agencies, and then those agencies can implement our recommendations to help address the lack of awareness of the problem of human trafficking, as well as fix issues that are routinely brought up in GAO reports (contracts missing CTIP clause, acquisition workforce not current on training, and a general lack of understanding of what human trafficking looks like).
The tool will also help the DOD CTIP PMO to run audits and identify areas of spend that could be shifted from Tier 3 countries to better rated countries. For example, if DLA is purchasing a certain PSC from a Tier 3 country, but the USAF is purchasing that same PSC from a Tier 1 country, that information can be shared to pull taxpayer dollars out of countries that are doing little to nothing to combat human trafficking (which is essentially the grounds for being rated Tier 3).