GSA OIG Flags Incomplete PBS Contract Files and CUI Marking Gaps

The General Services Administration Office of Inspector General (GSA OIG) found that the Public Buildings Service (PBS) did not provide adequate oversight of its electronic contract files or consistently designate and mark controlled unclassified information (CUI). The audit examined 11 closed contracts—one from each of the former PBS regions—and found every sampled file incomplete in the Electronic Acquisition System integration (EASi), PBS’s official system of record. The review covered contracts awarded in fiscal years 2022 and 2023 and closed in fiscal year 2024. The OIG cautioned that the sample was not statistically projectable to PBS’s broader contract population, so the results should not be treated as a measured error rate for all PBS contracts.

The findings nevertheless merit attention across a substantial portfolio: as of March 2026, PBS had 8,910 active contracts valued at more than $14.6 billion. EASi has been mandatory for PBS solicitations and awards above the micro-purchase threshold since May 1, 2018. Yet contracting officers told auditors that they did not consistently upload records into EASi, citing network drives, GSA’s Google Drive, and email as easier alternatives. They also described EASi as slow, difficult to use, and limited in functionality. After auditors requested records, PBS personnel added 956 documents to the sampled files, while some documents still could not be located. This points to a practical tension for contractors and acquisition teams: recordkeeping requirements depend not only on policy, but also on usable workflows and reliable, timely entry into the official repository.

The CUI findings add a separate information-handling concern. Some records were marked inconsistently or incorrectly, while documents containing acquisition plans, contractor personnel security information, and independent government estimates were not designated as CUI. The OIG said inadequate designation and marking increased the risk of unauthorized disclosure and mishandling of sensitive acquisition information. It attributed the deficiencies in part to PBS contracting personnel lacking a clear understanding of CUI requirements. For industry, this reinforces the need to follow contract-specific information-handling instructions, identify sensitive acquisition material appropriately, and coordinate with contracting officials when classification or marking expectations are unclear; the report does not establish new requirements for contractors, but underscores the consequences of inconsistent practices.

The audit also links record gaps to organizational and oversight challenges. PBS lost 49% of its acquisition personnel during 2025 staffing reductions, and the OIG reported that some departing personnel left incomplete files, requiring officials to search extensively for records during the audit. PBS also lacked a centralized contract-file review process after the Procurement Management Review Division within GSA’s Office of Government-wide Policy stopped conducting those reviews following a 2025 reorganization. The OIG issued four recommendations covering stronger file controls and timely EASi use, evaluation of EASi functionality, more consistent contract-file reviews and oversight of contracting officer’s representative (COR) records at closeout, and CUI guidance and staff training. Acting PBS Commissioner Michael Gelber concurred with the recommendations and said PBS is developing a corrective action plan aligned with acquisition-regulation changes and the consolidation of contracting divisions under the PBS Office of Acquisition Management.

• All 11 sampled PBS contract files were incomplete in EASi; the sample was not statistically projectable to the full contract population.
• The audit reviewed 11 closed contracts, one from each former PBS region, awarded in FY2022 and FY2023 and closed in FY2024.
• PBS personnel added 956 documents to sampled files after auditors requested records, but some documents could not be located.
• As of March 2026, PBS managed 8,910 active contracts worth more than $14.6 billion.
• EASi has been mandatory for PBS solicitations and awards above the micro-purchase threshold since May 1, 2018; personnel cited usability and functionality issues and used alternate storage locations.
• CUI issues included inconsistent or incorrect markings and missing designations on acquisition plans, contractor personnel security information, and independent government estimates.
• PBS lost 49% of its acquisition personnel in 2025 staffing reductions, while a centralized file-review process was no longer in place after reorganization.
• PBS agreed with four recommendations: improve file controls and EASi, strengthen file reviews and COR closeout-record verification, and provide CUI guidance and training.
• PBS is developing a corrective action plan; contractors should be prepared to support complete, timely documentation and follow applicable CUI handling instructions.