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U.S. Forest Service contracting under the Infrastructure Investment and Jobs Act (IIJA)

Forest Service Awarded $48 Million in Contracts It Can't Document

Summary

A USDA inspector general inspection found that 13 of 18 sampled Forest Service contracts funded by the 2021 infrastructure law were missing required pre-award paperwork -- acquisition plans, market research, solicitation reviews -- leaving $48.2 million the agency cannot demonstrate was competitively and reasonably awarded. Auditors are not recommending the money be recovered; the contracts are already finished.

By Augustus · July 17, 2026

A USDA Office of Inspector General inspection of Forest Service contracts funded by the Infrastructure Investment and Jobs Act found that 13 of 18 sampled contracts were awarded without one or more of the pre-award documents federal contracting rules require -- approved acquisition plans, market research, solicitation reviews, or public announcements of the award. The missing paperwork puts $48,255,403 in contract spending in a category auditors call unsupported costs: money the government cannot show was competitively priced, reasonably justified, or awarded in its own best interest, even though nothing suggests the work itself wasn't done.

A wildfire-risk law, and a contracting system that outran its own paperwork

The Infrastructure Investment and Jobs Act, signed November 15, 2021, gave the Forest Service roughly $5.5 billion to reduce wildland fire risk, restore ecosystems, and rebuild natural-resources infrastructure across the roughly 900 million acres of forest and grassland it manages. Between the law's signing and March 31, 2025, the agency pushed $277.8 million of that money out through 1,890 contracts -- everything from firm-fixed-price jobs to blanket purchase agreement calls, awarded through Forest Service offices in four procurement zones nationwide. 's inspection covered only the pre-award side of that pipeline: not whether the work got done, but whether the paper trail behind each award met the Federal Acquisition Regulation's own bar for how a contract file should read before money moves.

Unsupported contract costs
$48.2M
awarded on 13 of 18 sampled IIJA contracts missing required pre-award documents -- no recovery recommended
Sampled contracts with a documentation gap
13 of 18
72% of the contracts OIG reviewed were missing at least one required pre-award document
Total FS IIJA contract obligations
$277.8M
across 1,890 contracts, Nov. 2021-Mar. 2025, funded by IIJA's ~$5.5B for Forest Service lands
Forest Service IIJA contract obligations, by fiscal year
Dollars obligated through IIJA-funded contracts, November 15, 2021 - March 31, 2025
FY2022 (from Nov. 15, 2021)
51,400,000
FY2023
126,100,000
FY2024
96,900,000
FY2025 (through Mar. 31, 2025)
3,400,000
Source: USDA Office of Inspector General, Inspection Report 08801-0005-51 (March 2026), Figure 1
View data as table
The Forest Service obligated $277.8 million through 1,890 IIJA-funded contracts between November 15, 2021 and March 31, 2025 -- awards funded by the 2021 infrastructure law's roughly $5.5 billion for wildfire-risk reduction, ecosystem restoration, and natural-resources infrastructure on Forest Service lands. OIG's inspection found the pre-award files behind $48.2 million of that spending -- 17.4% -- missing documents federal contracting rules require.
FY2022 (from Nov. 15, 2021)51,400,000
FY2023126,100,000
FY202496,900,000
FY2025 (through Mar. 31, 2025)3,400,000

Eighteen contracts, thirteen with a hole in the file

Auditors pulled a judgmental sample of 18 -funded contracts worth more than $118.9 million, drawn from a universe of 1,303 contracts worth more than $543 million -- selected to cover the highest-dollar award in each fiscal year, the top 16 contracting offices that handle 90% of all funding, every award type the agency uses, and all four Forest Service procurement zones. Thirteen of those 18 contracts came back missing at least one required document. Across them, counted 17 separate gaps: four missing acquisition plans, five missing records of market research, seven missing or unapproved solicitation reviews, and one missing public announcement of the award. Solicitation review -- the step that checks a contract reflects the agency's actual needs and carries the legal clauses it's supposed to -- was the single most common gap.

Missing pre-award documents across the 13 flagged sample contracts
17 total document gaps identified across the 4 required pre-award document types
Acquisition plan missing
4
Market research missing
5
Solicitation review missing
7
Announcement of award missing
1
Source: USDA Office of Inspector General, Inspection Report 08801-0005-51 (March 2026), Exhibit B
View data as table
OIG reviewed 18 IIJA-funded Forest Service contracts against 17 required pre-award criteria and found 17 separate document gaps spread across 13 of those contracts -- most often a missing or unapproved solicitation review, the step meant to confirm a contract reflects the agency's actual needs and required legal clauses before it's awarded.
Acquisition plan missing4
Market research missing5
Solicitation review missing7
Announcement of award missing1

Why $48.2 million and not $53 million

Add up the value of all 13 flagged contracts and the number is $53,029,461, the figure lists in Exhibit B of the report. The $48.2 million figure in the audit's headline finding is smaller because auditors carved out one contract, worth $4,774,058, whose only defect was a missing public announcement of the award -- a procedural lapse judged didn't touch the substance of whether the contract itself was sound. The remaining $48,255,403 includes $19.6 million in direct obligations, with the rest of each contract's value coming from other funding the Forest Service blended in alongside the infrastructure-law money -- money that, by definition, was awarded through the same undocumented process.

No recovery, because the contracts are already done

is not asking the Forest Service to claw back any of the $48.2 million. The report is explicit about why: the contracts have already been executed, and most had already reached their completion dates by the time auditors finished fieldwork in February 2026. That leaves the finding as a records problem rather than a fraud finding -- but auditors pushed back hard on the idea that it's a minor one, writing that the missing acquisition plans, market research, and solicitation reviews are 'critical documents needed for making the determination that contract awards were reasonable, appropriate, and in the best interest of the Government,' and that without them the Forest Service simply cannot demonstrate its own acquisition process was sound.

The Forest Service agrees, and disagrees

The Forest Service's Chief, Thomas M. Schulz Jr., wrote back agreeing with both recommendations -- to evaluate the 13 flagged files and document what conclusions the agency reaches, and to build oversight controls so future contract files stay complete. But the agency drew a line at the dollar figure, telling the one or two missing documents per contract 'were not significant in terms of their impact on the underlying cost support or the determination that the contract awards were reasonable, appropriate, and in the best interest of the Government.' 's closing rebuttal didn't accept that: the same acquisition plans and market research the agency called insignificant are, in the FAR's own terms, the documents that establish whether an award was reasonable in the first place. The Forest Service's own timeline for closing the gap runs to February 18, 2027 -- nearly a year past the report's publication, for paperwork covering contracts that, in most cases, had already finished the work they paid for.

The takeaway

  • $48.2 million in Forest Service contracts have no documented basis for being reasonable, competitive, or in the government's best interest. That figure is not an estimate -- it's the exact value of the 13 sampled contracts (minus one carved out over a narrower gap) that were missing required pre-award paperwork, out of just 18 contracts reviewed.
  • Nearly three in four sampled contracts had a documentation gap. 13 of 18 -- 72% -- were missing at least one of an acquisition plan, market research, a solicitation review, or an award announcement; solicitation review was the single most common gap, at seven contracts.
  • No money comes back, and no one is accused of misusing it. isn't recommending recovery because the contracts are finished. The Forest Service agrees it needs better records going forward but disputes that the missing paperwork mattered -- a disagreement 's own rebuttal leaves unresolved, with a fix not due until February 2027.

's 18-contract sample was nonstatistical/judgmental, not a random statistical draw, so the $48.2 million and the 13-of-18 rate describe the sample chose to review -- built to span every fiscal year, the top 16 contracting offices, every award type, and all four Forest Service procurement zones -- rather than a projection onto the full $543 million contract universe it was drawn from. The inspection covered only the pre-award, contract-formation stage; it did not evaluate whether the funded work was actually completed or performed well.

Sources(2) ▾
  • U.S. Department of Agriculture, Office of Inspector General, IIJA – Forest Service Pre-Award Contracting Activities (Inspection Report 08801-0005-51) (2026-03-26) inspection of the Forest Service's pre-award contracting process for Infrastructure Investment and Jobs Act () funded contracts. Fieldwork May 2025-February 2026; results discussed with the Forest Service February 11, 2026; issued March 26, 2026. Reviewed a nonstatistical/judgmental sample of 18 -funded contracts (valued at more than $118.9 million) drawn from a universe of 1,303 contracts totaling more than $543 million. Includes the full finding, both recommendations, Exhibit A (summary of monetary results), Exhibit B (per-contract issue breakdown), Exhibit C (the 17 pre-award evaluation criteria), and the Forest Service's full written response with the 's rebuttal. Fetched directly from oig.usda.gov and read in full (all 24 pages, including exhibits and the agency-response appendix). oig.usda.gov · original document
  • U.S. Department of Agriculture, Office of Inspector General, IIJA – Forest Service Pre-Award Contracting Activities (report landing page) (2026-03-26)Official report index entry confirming the inspection report number, issue date, and providing the direct PDF link used as this piece's primary document. oig.usda.gov · original document
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