PREFACE
The NASA Headquarters Office of Procurement conducted this procurement management survey at the Stennis Space Center (SSC) under the authority of NASA Procedures and Guidelines 1000.3, The NASA Organization. The survey was conducted from May 22 through May 25, 2005. The report contains the survey strengths, weaknesses, and considerations.
An exit briefing was held on May 25, 2002 to discuss the survey findings. The Center Director and Procurement Officer represented SSC at the briefing. The Assistant Administrator for Procurement and the leader of the survey team represented NASA Headquarters.
This report serves as a basis, in part, for fulfilling internal control requirements in accordance with the Federal Manager's Financial Integrity Act of 1982 (P.L. 97-255).
Jerry P. Edmond
Survey Program Manager
Office of Procurement
Analysis and Assessment Team
SECTION II ORGANIZATION — MANAGEMENT
SECTION V GRANTS, COOPERATIVE AGREEMENTS, SIMPLIFIED ACQUISITIONS, AND OTHER ISSUES
SECTION VI SMALL AND DISADVANTAGED BUSINESS (SDB) UTILIZATION
SECTION I
The Procurement Organization at the Stennis Space Center is providing meaningful support to their program customers. The Procurement Management Survey Team interviewed randomly selected technical and program representatives to ascertain any issues or concerns with the current processes. A significant degree of customer satisfaction is apparent from the interviews with the technical community. Additionally, interviews with numerous acquisitions professionals at all levels of the SSC organization regarding the effectiveness of the procurement office were also conducted. The consensus from the procurement staff was also positive.
The interviews of technical and acquisition personnel are given roughly equal survey emphasis with a review of contracting actions focused on compliance with procurement statutes, regulations, and procedures. The thrust of the compliance portion is directed towards systemic procurement processes, as opposed to focusing on individual file anomalies. Attention was also directed to current procurement innovations, both Agency-wide and Center specific.
The results of the compliance reviews and the interviews are detailed as strengths, weaknesses, and areas of consideration. Also, to promote the exchange of successful lessons learned and innovative procurement methodologies between Centers, the team sought to identify SSC processes or initiatives that might benefit other Centers and, likewise, looked to other Centers for suggested approaches that might be exported to SSC.
The exit conference at the conclusion of the survey consisted of a direct exchange of observations and ideas between the participants. To emphasize Center ownership of the resolution of any identified weaknesses or considerations, the survey follow-up process will focus on the corrective actions or initiatives undertaken by the Center. At an appropriate interval (approximately six months after this report is issued) the SSC Procurement Officer will brief the Assistant Administrator for Procurement and the survey team leader on Center achievements in these areas.
Below is a list of team members and the areas they reviewed:
JERRY P. EDMOND (NASA/HQ) |
Survey Team Manager, Interviews (Legal, 1102, & COTR), and Metrics |
HAROLD JEFFERSON |
Contracting Actions Resulting from Katrina, UCAs, Closeouts & ULOs, Self Assessment, Contractor Insurance and Pension Reviews |
YOLANDE HARDEN |
Internal Policies and Procedures, COTR and 1102 Training, Contractor Performance Evaluations-NF 1680, and Contractor Safety Requirements |
MICHELÉ HULL |
Grants & Cooperative Agreements, Contracts for Administrative or Office Support, Environmental Issues, Bankcard Program, and Property |
JOE CAMPBELL (JSC) |
Pre/Post Negotiation Memorandum, Technical Evaluations, Cost/Price Analysis, and Audit Follow-up |
PAT LOGAN (GSFC) |
Construction Contracts, Commercial Acquisition, Simplified Acquisitions, NF-533, SBIRs, and Competition under IDIQ Contracts |
STEVE MORRIS (MSFC) |
Adequacy of documentation for Awards Resulting from Broad Agency Announcements, Exercising of Options, Inter-Agency Awards, JOFOCs/Competition Advocacy, CPAF/IF Contracts |
SHIRLEY PEREZ (HQ-OSDBU |
Small and Disadvantaged Business Utilization |
The survey could not have been accomplished successfully without the support of the following individuals:
| BEVERLY SMITH |
Procurement Data Support |
| DONNA SPRINKLE | Procurement Data Support |
| SUSIE MARUCCI | Headquarters Administrative Support |
|
REBEKAH BREWER |
Headquarters Administrative Support |
| ROBERT HARRIS | SSC Point of Contact |
| TERRI DEUTSCHMAN | SSC Administrative Support |
1. Organization Structure and Staffing:
Since the 2002 survey the organizational structure of the Acquisition Management Office is unchanged. The AMO is still under the Business Management Office (BMO) with the Procurement Officer reporting to the head of the BMO. There are still two functional areas, the Operations Contracting Division and the Support Services Division, responsible for providing acquisition support directly to SSC customers. Each of these areas is lead by a GS-14 team lead who also reports to the Procurement Officer. There is a Deputy Procurement Officer who reports to the Procurement Officer. AMO has a Policy and Pricing Group, who are responsible for a wide array of functions including procurement policy, the bankcard program, pricing, and small business utilization. However this group doesn’t have a team lead and each individually reports to the Procurement Officer. Currently there are 20 employees (including the Procurement Officer and Deputy Procurement Officer) housed in the AMO. Two of the 20 are term employees and one is active military.
The Procurement Officer has submitted a plan to reorganize her office which is awaiting approval. The plan when approved would essentially create three divisions. The proposed Program Management Support and Center Management Support Divisions would be responsible for providing acquisition support to the SSC customers. The third division created would be called the Procurement Management Support Division; it will perform policy functions (i.e. SAP/CMM, Policy, Pricing, Small Business, Training, etc.). This division would have a team lead and significant increase in staff. Currently, three full time equivalents (FTEs) perform the policy function; the reorganization plan would call for 5 FTEs. The other two offices would each have staffs of 7. The reorganization would increase staff from 20 FTEs to 26 FTEs.
2. Procurement Staff Interviews:
Interviews were conducted with eleven members of the SSC procurement workforce ranging from the most junior individuals to senior personnel in the SSC AMO to gain insight into the effectiveness of the procurement organization.
Overall employees believed that their co-workers were professional and that they assisted one another when needed whether helping each other with their workload when someone was out or through communicating ideas with one another. Most employees believed morale was good and that the Procurement Officer, Deputy and Team Leads were accessible. Most employees stated that they received feedback on their work products throughout the year not just at performance appraisal time. Most employees believed that Individual Developments Plans (IDPs) were value added and were used to help develop career paths and training goals.
Employees were very pleased with the level of support shown during the Katrina disaster. The employees stated that management allowed them time off to tend to personal matters that came as a result of the hurricane. Employees also stated that Center management took steps to help improve morale after the Hurricane.
Newer employees (those hired in the last 2 years) voiced concerns about the Stennis Work Request (SWR) Process. The work request process is used on a majority of the contracts at the Center. There was a perception among the newer employees that this process was open to misuse by the customers and contractors. Furthermore, many of them were having a hard time trying to understand the process. It is suggested that the Procurement Officer take the necessary steps to educate the employees more thoroughly about the process.
Employees interviewed believed they had good relationships with their technical customers. The perception from the last survey that technical customers only involved procurement at the end of the procurement process to just do the paperwork no longer exists. Employees believed that their technical counterparts saw them as a valuable member of the team and respected them as professionals.
Most employees believed they had a good working relationship with Legal Counsel. However, a number of employees voiced concerns about the length of time it takes the Office of Chief Counsel to review documents. However, they did note that the Chief Counsel’s office has had a lot of turnover which may have attributed to the problem.
A number of employees believed that work was distributed fairly. However, a majority of the employees felt overworked and would appreciate more help in the office. They noted that the NASA Shared Services Center (NSSC) has taken a significant portion of their workforce. They also were concerned that there is a perception that the NSSC had higher grades for work with less complexity. It is suggested that the Procurement Officer work with Center management to take steps to raise the grade level in the organization to compete for human capital with the NSSC.
Finally a number of employees voiced concerns with the process for training interns. The employees who discussed this issue believed that there were not processes in place to help new employees come up to speed to gain insight in the actual day-to-day procurement process. Employees suggested that aside from what’s on the web it may be beneficial to create a desk reference to help guide employees on how to implement AMO work process. It is suggested that the SSC Procurement Officer contact the Procurement Officer at GSFC to discuss the GSFC new employees’ reference guide, which was created to help new employees become familiar with NASA and GSFC work processes. It is also suggested that the Procurement Officer contact the MSFC procurement officer to discuss the MSFC Procurement Mentoring process in order to gain insight in to how their mentoring process is implemented.
STRENGTHS:
(1) The SSC Procurement Officer, Deputy Procurement Officer, and team leads are commended for being accessible to their employees and for creating a good work environment.
(2) The SSC Procurement Officer, Deputy Procurement Officer, and team leads are commended for being supportive of their employees during the Katrina disaster.
CONSIDERATIONS:
(1) It is suggested that the SSC Procurement Officer implement training in order to give employees a clearer understanding of the SWR Process.
(2) It is recommended that the SSC Procurement Officer work with Center management in order to raise the grade structure within the Office of Procurement in order to compete for Human Capital with the NSSC.
(3) It is recommended that the SSC Procurement Officer contact the Procurement Officers at GSFC and MSFC in order to gain insight into improving intern training.
3. Customer Interviews:
A total of six AMO customers representing a cross-section of the Center were interviewed regarding their level of satisfaction of support received from the AMO. The customers selected for the interviews were done randomly and were either Contracting Officers Technical Representatives (COTRs) or Alternate COTRs on Contracts.
Overall the customers were very satisfied with the level of service received from the AMO. Customers commented that the AMO staff was very professional and that the service they received was timely. Also, the customers interviewed believed the AMO produced good work products and provided them with useful samples when the need arose to do technical evaluations or Justifications for Other than Full and Open Competition (JOFOCs).
Most of the customers interviewed believed the COTR training was very good. One customer voiced an appreciation for someone from AMO being present at the COTR training in order to translate information into NASA and SSC language. A suggestion for training that came out of the COTR interviews was to allow future COTRs shadowing opportunities where they shadow more experienced COTRs in order to gain insight into the day-to-day activities of the COTR function. It is suggested that the Procurement Officer work with SSC Center management to implement a program of this nature. All of the customers interviewed received their COTR delegation forms.
STRENGTH:
The SSC AMO personnel are commended for effectively meeting their customer needs and for providing excellent customer service.
CONSIDERATION:
It is suggested that the SSC Procurement Officer work with Center management to implement shadowing opportunities for future COTRs so that they can gain insight into the day-to-day activities of a COTR.
4. Chief Counsel Interview:
The head of chief counsel was interviewed to gauge the working relationship between the Office of Chief Counsel and the AMO and to determine the quality of files produced in the AMO. The Chief Counsel stated the Office of Chief Counsel has a good working relationship with the AMO. Furthermore, the Chief Counsel believes that the quality of files has significantly improved and the improvement can be directly attributed to the efforts of the Procurement Officer. Chief Counsel expressed great respect for both the Procurement Officer and the Deputy Procurement Officer.
He was very impressed with the Deputy Procurement Officer’s handling of the FEMA trailer procurement, including the exit strategy implemented to allow FEMA to take over management of the trailers from NASA.
The Chief Counsel expressed that construction contracting has improved and that improvement can be attributed to the efforts of Jason Edge.
Chief Counsel also expressed that the AMO has done a great job of hiring new people due to significant personnel loses to NSSC.
The Chief Counsel did express two concerns. The first concern was with the quality of the JOFOC files. He believes the requirements personnel in the field produce JOFOCs that are substandard, and they get passed through the Procurement review process. Also, he has concerns about the significant increase in construction contracting that is about to get underway at the Center. He doesn’t believe at this time that the AMO has sufficient staff to implement the increase in requirements in that area.
Finally, he believes the monthly brown bag luncheons held between AMO and Chief Counsel has improved the relationship between the two offices. At these brown bag luncheons a member of AMO staff or Chief Counsel present topics related to procurement. These informal training sessions are held monthly.
STRENGTH:
The SSC Procurement Officer and the Chief Counsel are commended for taking steps to improve the relationship between the two offices.
CONSIDERATION:
The SSC Procurement Officer should implement training in order to improve the quality of JOFOCs produced by the AMO.
5. COTR Training:
The Stennis Office of Human Capital training office maintains a database of current COTRs with certification expiration dates. COTR training courses are arranged through the Office of Human Resources along with other Center sponsored training. The courses are provided through the Glenn Research Center contract for COTR training. The list of active COTRs is shared with the Office of Procurement for tracking purposes. This list identifies individuals that have received COTR training as well as the 5-year training expiration dates. The Office of Procurement also maintains a list of the current contracts that identifies the COTR, alternate and required refresher dates. Of the 129 individuals listed in the database of active COTRs, 9 did not have current training. All COTRs assigned to active contracts had current training.
STRENGTH:
The SSC AMO should be commended for updating the list of active COTRs and working with the Center Training Office to ensure that the majority of COTRs have current training.
6. 1102 Training:
The Stennis training coordinator maintains a database that tracks procurement employees’ level of training, grade, warrant status, and educational background. The database also reflects the completion dates for contracting certification courses. There are currently 17 employees in the Stennis procurement organization; all have received the appropriate level of training for their grade and length of service at the Center. One recently hired employee with a background in accounting is currently working on his Level I certification.
Training records are well documented and the files contain extensive information including copies of course certificates, Department of Defense data profiles and Defense Acquisition University transcripts. While the contracting certification requirements are tracked within the Office of Procurement, all other employee training is tracked through a database maintained by the Training Office within the Stennis Office of Human Capital. The employees work with the Procurement Officer and Team Leads to develop Individual Development Plans to assist in meeting the continuing education requirements and general career development plans. The Procurement Officer indicated that the travel budget for training in recent years is typically cut in half and it has an impact on the amount of training courses outside of the Headquarters-sponsored training courses that employees are able to attend.
1. Pre-Negotiation and Post-Negotiation Documentation:
Files were reviewed to determine if they addressed the requirements at NFS 1815.406-170 for a pre-negotiation position memorandum and NSF 1815-406-3 for a negotiation memorandum. The pre-negotiation position memorandums reviewed documented the Government's position.
The Cooperative Agreement, Phase II SBIR, and GSA BPA order files reviewed integrated price/cost analysis, technical evaluations, and audit reports or rate verifications into the basis of the Government's price/cost objective.
For contract modifications all the files reviewed included both pre and post price negotiation memorandums. This represents a great improvement since the last survey in 2002. The memorandums reviewed summarized the procurements and indicated the results of negotiation in accordance with FAR 15.406-3. Some minor issues were noted with the price negotiation memorandums. These documentation issues included not closing the loop on how system audit issues will be corrected such as accounting systems that are identified as partially inadequate by DCAA. Also, the memorandums stated that the price/cost analyst preformed an evaluation, but in some cases the file did not include a price analysis evaluation report.
2. JOFOC’s/Competition Advocacy:
Five non-competitive award files were selected for review. Dollar values ranged from $80,000 to $72,000,000. Three files reviewed used the authority at 10 U.S.C. 2304 (c) (1) and two of the files cited the authority at 10 U.S.C. 2304 (c) (3). All five of the files met the content requirements of FAR 6.303.2.
The three files citing the (c) (1) authority included pre-solicitation synopsis notices, but two of the JOFOCs were approved prior to the close of the synopsis period. Both of those JOFOCs contain language that states the JOFOCs will be updated with the results of the synopsis, but there is no evidence in the file that this was done. Neither file addresses whether or not any responses were received to the synopsis notice.
One of the JOFOCs citing the (c) (3) authority was to a Federally Funded Research and Development Center (FFRDC) and the JOFOC states the entity is the only known source that possesses the depth in technical knowledge and expertise to accomplish the effort. The JOFOC does not say the use of the authority is to maintain an essential engineering, research, or development capability to be provided by an FFRDC. The requirement was not synopsized. It appears that the authority cited does not coincide with the reason stated for citing the authority. The (c) (3) authority should have been supported by a discussion of the need to maintain an essential engineering, research or development capability, while (c) (1) is the appropriate authority if the vendor is the only source and should be supported by the appropriate market research and a pre-solicitation synopsis.
The other JOFOC citing (c) (3) also discusses the entity’s unique capabilities and again does not address the need to maintain an essential engineering, research or development capability. This action was synopsized but the JOFOC was approved prior to the synopsis period closing, and there isn’t anything in the file addressing whether or not there were any responses to the synopsis.
WEAKNESS:
SSC Procurement Officer should ensure that JOFOCs are approved only after the results of the pre-solicitation synopsis are known. SSC should ensure there is file documentation addressing any responses to the synopsis and how those responses were dispositioned.
CONSIDERATION:
SSC Procurement Officer should ensure that the use of the (c) (3) authority in a JOFOC is supported by an explanation why it is essential to maintain the required engineering, research or development capabilities. If the justification cites the firm’s unique capabilities and states it is the only capable source then the JOFOC should cite the (c) (1) authority.
3. Documentation for Awards Resulting from Broad Agency Announcements (BAAs):
Five files were selected for review. One award was the result of a SSC released Cooperative Agreement Notice (CAN). Three awards were the result of Headquarters’ CANs, and one award was the result of a Headquarters’ released BAA.
NFS 1835.016-71 (d) (8) identifies the documents the selection official shall provide to the contracting officer that will execute the award. This includes a copy of the BAA, the proposal, selection statement, results of the technical evaluation, total number of proposals and a listing of the proposals selected for funding. Also to be provided is a description of any changes desired in an offeror’s statement of work. If a contract will be the award instrument, a description of the deliverables should be provided.
The award files for three of the four HQ issued announcements only included copies of the CAN and the proposal. The file for the fourth HQ issued announcement included copies of the BAA, proposal, selection statement, technical rating and identified the deliverable for the resulting contract. The award file resulting from the SSC released CAN included all required documentation.
NFS 1835.016-71 (b) (1) requires that field generated announcements be approved by the installation director or designee, with concurrence of the procurement officer and each HQ generated announcement be approved by the cognizant Program Associate Administrator or designee, with concurrence of the HQ Office of General Counsel and Procurement. None of the five award files reviewed contained these approvals.
WEAKNESS:
SSC Procurement Officer should ensure that award files for all BAAs, NASA Research Announcments (NRAs) and CANs include all documentation required by NFS 1835.016-71 (d) (8) and all approvals and concurrences required by 1835.016-71 (b) (1).
4. Technical Evaluations:
Eleven technical evaluations were reviewed to ensure that the documentation complied with the requirements established in the FAR and NFS. Based on the files reviewed, it appears the Cooperative Agreements, Phase II Small Business Innovation Research (SBIR) and other lower dollar value actions had excellent technical evaluations. On the other hand, the larger dollar value contract modifications did not. This is interesting since AMO personnel were commended for providing well-crafted technical evaluation request letters that aided the technical personnel in preparing their evaluations during the last survey in 2002. Technical evaluations should provide an assessment of the following: the proposed costs, including skill-mix; total hours or FTEs; the schedule; the equipment, supplies, and materials; and the travel, subcontract cost, and other direct costs items.
CONSIDERATION:
SSC Procurement Officer should take appropriate action to ensure technical evaluations include all essential information needed to conduct cost and pricing analysis in accordance with the FAR and NFS.
5. Cost and Price Analysis:
The Survey Team reviewed eleven contract files for adequacy of cost and price analysis. Overall, Cooperative Agreement, Phase II SBIR, and GSA BPA order files were adequately documented and supported the price reasonableness of negotiated prices. When appropriate, the structured fee approach, NASA Form (NF) 634, was used to develop the basis for profit or fee. For modifications, the CO based the fee on the competitively determined fee rate from the basic contract. Primarily due to issues with the technical evaluations the cost analysis appears to be overly dependent on DCAA input. The price analyst should receive input on labor resource and Other Direct Cost (ODC) quantities from the technical staff, receive rate information from DCAA, and combine these into a model based on the contractor’s proposal to develop a probable cost objective.
STRENGTH:
The skills and support provided by the cost/price analyst to the procurement personnel is an excellent resource.
CONSIDERATION:
The reports provided by the price/cost analyst to the contracting officers are lacking any reference to “price analysis” as a separated and distinct step in the evaluation process from the “cost analysis” preformed. A brief price analysis section applying one or more of the price analysis methods described in FAR 15.404-1(b) should be added to these reports.
1. Contractor Performance Evaluation-NASA Form (NF) 1680:
NFS 1842.1502 requires contracting officers to conduct evaluations of contractor performance within 60 days of the award date anniversary for all contractors with contracts greater than $100,000. The NFS further states that award fee and hybrid contracts do not require completion of the NF 1680. However, PIC 01-12 dated June 15, 2001 states that award fee evaluations must be summarized on the NF 1680 and entered into the Past Performance Database (PPDB). Further, the clarification between the PIC and the NFS language has been discussed on numerous occasions during the monthly Procurement Policy telecoms. It is noted that the NFS should be amended to provide clear policy direction.
The SSC AMO has an official work instruction regarding the Contractor Past Performance Database. It contains a description of responsibilities and procedures for documentation. Paragraph 5.0 indicates that “award fee contracts, incentive fee contracts, hybrid contracts containing both award fee and non-award fee portions, etc.” are exempt from the requirements and may be entered into the PPDB at the contracting officer’s discretion. This instruction is inconsistent with PIC 01-12 that stipulates the inclusion of summarized information for award fee contracts in the PPDB.
The SSC AMO has been inconsistent in its adherence to the FAR and NFS policies regarding the collection of contractor performance evaluations. Six contract files were reviewed for compliance. Four contracts contained no file documentation (i.e., NF 1680), and no information in the PPDB. In some cases the contract checklist (NF 1098) indicated that documentation was contained in separate files; however, either the file tabs were empty or there were no file tabs associated with past performance evaluation. One of the contracts is an award fee contract where the award fee evaluations were properly and thoroughly documented; however, no summary information was included for past performance evaluations. Another contract’s award anniversary was recently completed and still within the 60 days allowed by the NFS. (Note: the contracting officer provided a copy of a completed NF 1680 with contractor’s comments during the course of the file review for one of the aforementioned contracts.)
Two contracts reviewed contained past performance evaluation documentation for prior evaluation periods but not for recent periods. In one case both the contract file and the PPDB contained information, while in the other case information was only found in PPDB. There is evidence of draft reports that were recently created (March 2006) for evaluation periods for three contracts reviewed, but they have not yet been completed.
A review of the PPDB database for SSC contracts reveals that past performance evaluations have not been conducted and entered into the system with any regularity for the last two to three years. Further, there are several incomplete ‘draft’ evaluation reports in the system, some dating back to 2002. It also appears that several reports were recently created in the system for multiple evaluation periods, however these are also incomplete.
WEAKNESS:
The SSC Procurement Officer should ensure that contractor performance evaluations are conducted in a timely manner consistent with the requirements of FAR 42.15 and NFS 1842.15. The information entered into the Past Performance Database should be saved as permanent records and not remain in draft form for an indefinite period of time. Contracting Officers should ensure that adequate narrative descriptions of the contractor’s performance is included in the database and in the case of award fee or incentive fee contracts, a summary of the award/incentive fee evaluation results is included.
CONSIDERATIONS:
(1) The Headquarters Contract Management Division should take steps to amend the NFS 1842.15 to clarify the requirement of the inclusion of summary contractor performance information on award fee, incentive fee and hybrid contracts in the Past Performance Database.
(2) The SSC AMO should amend its work instruction SWI-5100-0006 dated November 4, 2004 to require the inclusion of summary contractor performance information in the Past Performance Database on award fee, incentive fee and hybrid contracts.
2. Cost Plus Award Fee/Cost Plus Incentive Fee Administration:
Two award fee files and three incentive fee files were reviewed. Award fee evaluations followed the applicable award fee evaluation plans, were well documented, and thoroughly supported the fee determination in each contract file that was reviewed. The files contained extensive minutes of the Performance Evaluation Board meeting explaining the decisions that were made. Award fee payments were made within the 60 day time frame required by NFS. Incentive fee evaluations followedthe applicable incentive fee criteria and were also well documented.
STRENGTH:
The award fee files contained excellent documentation that fully supported the fee determinations and payments were made within the required time frame.
3. Closeout and Unliquidated Obligations (ULOs):
The team review of closeouts and unliquidated obligations consisted of trend analysis, closeout schedule time frame by contract type, use of quick closeout procedures, open actions, and overage ULOs for the closeout of completed contracts, purchase orders, grants, cooperative agreements, inter-agency agreements and the status of unliquidated obligations.
The Agency closeout contractor, BRACE Management Inc., provides support to the SSC Procurement Office. BRACE is responsible for preparing all closeout documentation for the Contracting Officer’s review and approval. The procurement office monitors one action (Johnson Controls) outside of the BRACE responsibilities due to litigation. However, the Procurement Officer should ensure that any future contracts with Johnson Controls be closed out by BRACE. BRACE has a database that tracks and reports an open contract population, action plan, overage not closed, and a monthly report reflected actions closed. The overage report reflects why the actions are over due, for example, pending DCAA audits, property issues, additional funding requested, final invoices, and disallowed cost pending. As of May 23, 2006, SSC has 37 physically completed actions which are not administratively closed where obligated monies are not yet liquidated. Nine of these actions are overage pending receipt of final documentation. The unliquidated amount for these actions is approximately $1.1M.
STRENGTH:
The SSC Procurement Officer is commended for focusing on closing out contract actions and maintaining a low ULO percentage rate.
4. Undefinitized Contract Actions (UCA’s):
SSC historically has issued a low number of UCA’s. The team reviewed the one outstanding reportable UCA. The file review focused on age, dollar value, appropriate approval level, justification and file documentation in accordance with NFS 1843.70. Overall the file documentation prior to the issuance of undefinitized contract action was well documented.
CONSIDERATION:
The SSC Procurement Officer should ensure that an official contractor funding profile has been obtained from the contractor prior to issuance of any UCA exceeding $1M.
5. Financial Management Reporting - NASA Form (NF) 533:
Four contract files were reviewed for compliance with NFS 1842.7201, NASA Contractor Financial Management Reporting. All contracts included the contract type, dollar thresholds requiring financial management reporting and NFS clause 1852.242-73 requiring NASA Contractor Financial Management Reporting. This clause requires that the detailed reporting categories to be used shall be set forth in the contract, as well as the number of copies and time and manner of submission.
Contracts NAS13-650 and NAS13-99030 contained a detailed breakout of reporting categories.
NFS 1842.7201(a) (1) requires contracting officers to monitor contractor cost reports on a regular basis to ensure cost data reported is accurate and timely, and to pursue adverse trends and discrepancies discovered in cost reports through discussions with financial and project team members. All files contained memos from the contracting officers stating that the cost reports were reviewed on a monthly basis with the contractors and the cognizant NASA technical and financial personnel regarding cost, budget, and performance. There was no record of any findings of untimely or inaccurate reports, any issues found, or any actions required or taken in this area.
6. Competition under Multiple Award Task and Delivery Order Contracts:
SSC has not awarded any multiple award contracts where the subsequent delivery or task orders are competed among the awardees. All task order files reviewed were for specific contracts authorizing issuance of tasks, and, therefore, no competition for the individual tasks took place, only for the contracts themselves. As stated in the previous survey, SSC needed to consider the multiple award IDIQ approach for two follow-on contracts ending in 2003. However, they currently have only two task order contracts Boeing/Rocketdyne and Paragon systems. Neither of these contracts was the result of multiple awards. Several task/delivery orders under these contracts were reviewed. There was no evidence in the file that any market research was done prior to placing the order to determine if placing a delivery order was the best value versus a competed requirement. FAR Part 10 does not specifically require market research when placing a task/delivery order, but this approach could be very useful.
CONSIDERATIONS:
(1) SSC AMO should consider the benefits of multiple award contracts and utilize them when technically and programmatically feasible in the future.
(2) SSC AMO should conduct market research before placing task/delivery orders against IDIQ contracts to determine if the existing contract is the most advantageous method of meeting the Government’s needs.
7. Options to Extend Performance:
The team reviewed five modifications that implemented options to extend the term of the contract. Four of the five modifications included a determination documenting the decision to exercise the option. Two of the four determinations met all the requirements of FAR 17.207 and NFS 1817.207-70. The other two determinations addressed all requirements of the determination except for FAR 17.207 (d) which says “ The contracting officer, after considering price and other factors, shall make the determination on the basis of one of the following:
(1) A new solicitation fails to produce a better price or a more advantageous offer than that offered by the option. If it is anticipated that the best price available is the option price or that this is the more advantageous offer, the contracting officer should not use this method of testing the market.
(2) An informal analysis of prices or an examination of the market indicates that the option price is better than prices available in the market or that the option is the more advantageous offer.
(3) The time between the award of the contract containing the option and the exercise of the option is so short that it indicates the option price is the lowest price obtainable or the more advantageous offer. The contracting officer shall take into consideration such factors as market stability and comparison of the time since award with the usual duration of contracts for such supplies or services.”
The fifth file reviewed exercising an option did not contain a determination to exercise an option. Also the modification exercising the option was signed on March 3, 2006, but the effective date (block 3 of the SF 30) shows a date of June 17, 2005. The file provides no explanation for this other than stating the modification had to be exercised bilaterally due to an oversight on the part of the Government. This error appears to be an isolated incident.
WEAKNESS:
SSC AMO should ensure all determinations to exercise options fully meet the requirements of FAR 17.207. (Repeat Finding)
8. Contractor Insurance/Pension Reviews (CIPRs):
The team reviewed contract files to ensure that a thorough analysis of the contractor’s insurance/pension plans, related policies, procedures and practices, and costs to determine whether they are in compliance with the rules and regulations. The procurement staff readily uses the DCMA/DCAA local offices to review and monitor contractor insurance and pension plan activities for the International Space Station and Space Flight Operations Contract programs. The files did not contain the necessary information indicating that a review had been conducted on contractor insurance and pension plan activities for cost type contracts with $40M or more of sales to the government during the previous fiscal year.
WEAKNESS:
The SSC Procurement Officer should ensure that the CIPRs are taking place for Contractors with sales of $40M dollars or more to the federal government during the previous fiscal year.
CONSIDERATION:
The SSC Procurement Officer should ensure that individuals transferred to more complex contracts with contractor insurance/pension review requirements be tutored if they don’t have prior contractor insurance/pension review experience. The SSC Procurement Officer should validate that the Administrative Contracting Officer has performed such reviews and forwarded the findings to the Contracting Officer.
9. Government Furnished Property (GFP):
The review of GFP focused specifically upon the use of appropriate property clauses, compliance with NF 1018 reporting, and review of requirements by the Supply and Equipment Management Officer (SEMO). In addition, files were reviewed to ascertain whether a Determination and Findings (D&F) required by FAR 45.302-1(a)(4) and the contracting officer rationale required by 1845.302-1(a)(iv) were included in the file.
In one of the files reviewed, the pre-negotiation memorandum stated that, “The Government will provide real and installed property, equipment, materials, supplies, and utility services in sufficient quantity to enable the Contractor to perform the work under this contract.” However, the FPDS-NG entry did not show the box checked for “GFE/GFP Provided Under This Action”, nor was there reference on the NF 1098 that there was a List of GFP (Tab 20 on the NF1098), SEMO Review, or a Determination for property in the file. It was also not evident that NF 1018 forms were being submitted annually.
Files reviewed did not contain D&Fs for property, nor did they include the NF 1018 reports. It appeared that all the pertinent property clauses were included in the contracts.
WEAKNESS:
The SSC Procurement Officer should ensure D&Fs and NF 1018 reports are properly documented in the contract files.
10. Safety and Health Requirements:
The Safety and Health provisions and clauses prescribed in the NFS were applied appropriately to the seven contracts reviewed. The necessary safety and health plans were incorporated into the contract when required. In many cases on the larger dollar value contracts the plans were incorporated as part of the Data Requirements Documents.
The Work Instructions for the Procedures for the Review and Approval of Procurement Documents did not include a review requirement for the Safety and Mission Assurance organization for solicitations or contracts containing safety and health plans. Some files did contain evidence of reviews by Quality Assurance representatives when Quality Plans were required in the contracts.
CONSIDERATION:
The SSC Procurement Officer should consider including Safety and Mission Assurance representatives in the review process for solicitations and contracts that contain requirements for Safety and Health plans.
11. Audit Follow-Up:
SSC AMO currently has no outstanding reportable audits. Nevertheless, SSC AMO has established a system to assure the prompt and proper resolution as well as implementation of audit recommendations. This system provides for a complete record of actions taken on findings and recommendations. SSC AMO uses a simple manual suspense system that is managed by the Procurement Officer’s secretary. The SSC AMO process is for the Procurement Officer to assign a number, due date and a responsible person to the all reportable audits that require SSC resolution or implementation.
For locally requested DCAA audits, the Price Analyst performs follow-up tracking on systemic issues with the contractors with whom SSC AMO has a continuing relationship. These issues include items that effect more than one contract action such as accounting systems that DCAA has determined to be inadequate and may not be immediately correctible during the course of any one contract action negotiation.
STRENGTH:
SSC AMO’s approach to audit follow-up and manual suspense system enables effective tracking of reportable audits and minimizes the risk of failure associated with unnecessary complex systems.
Three grants and two cooperative agreements were reviewed to assess compliance with applicable regulations and guidance in the awarding of these documents.
The Principal Investigator’s name appeared to be listed in all five grant and cooperative agreement documents reviewed.
Two of the four grants were awarded with an effective date that was earlier than the award date and in one case even before the negotiation completion date. In one the effective date was 21 days prior to the Grants Officer signature on the award document and 21 days prior to the signature of the negotiation summary document by the Grants Negotiator.
In reviewing the files, it was observed that the price/cost analysis usually consisted of a few simple statements such as the technical evaluation took no exception to the proposed budget. There was no supporting documentation in the file to form a basis that these rates were fair and reasonable. SSC should document the price/cost analysis to include records of telephone conversations or rate verification rate sheets.
The requisite delegation accpetance letters, grant and cooperative agreement checklists, Program Manager (COTR equivalent), and designation letters were not contained in the files.
WEAKNESSES:
(1) SSC should perform a more thorough price/cost analysis that includes rationale as to why prices/costs are fair and reasonable. (Repeat Finding)
(2) The rationale behind the need to have effective dates prior to the award date needs to be documented in the file. (Repeat Finding)
CONSIDERATION:
SSC Procurement Officer should ensure that files contain the requisite delegation acceptance letters, grant and cooperative agreement checklists, Program Manager (COTR equivalent), and designation letters.
2. Simplfied Acquisitions:
Files were reviewed to ensure compliance with FAR and NFS. In the previous survey, purchase order file documentation was found to be inconsistent among the various buyers. Some buyers use the bid abstract to document quotes and others use the Simplified Acquisition/Delivery Order Documentation Sheet; however SSC Procurement Management has shown significant improvement in the completeness and consistency of purchase order files. Work instruction SWI-5100-0003 lays down specific instructions on file documentation for simplified acquisitions. In all cases the correct file documentation was in the file.
Several GSA delivery orders were reviewed. In all cases, the requirements of FAR 8.404 were followed. Competition was sought in all cases. However there was not much success in obtaining competition from other GSA sources. GSA provides a list of many schedule holders for the choosing, however, many companies may not have the capability to perform the requirement. It would be a good idea to contact potential companies to determine interest in the requirement before soliciting. There was no evidence that this was done in any of the files.
Price reasonableness determinations - All files contained the required form SSC-9 – Small purchase Pricing Sheet denoting the basis for determining the reasonableness of proposed prices, however the files did not contain objective evidence to support the determination. In particular, GSA actions contained the statement that “GSA has determined that the pricing is fair and reasonable”, as the basis for acceptance of proposed prices, however FAR 8.404(d) encourages agencies to seek additional discounts before placing an order. There was no evidence that additional discounts were sought.
The purchase Order Documentation sheet SSC-8 does a good job of denoting all of the file requirements. However, every file contained that statement that the form NF1707- Certification and Special Approval for IFM Purchase Requisitions was in the file, however, the certification was not present in many files. All files contained a CCI memo that documents the action taken after reviewing the CCI web page. All files that are closed out contain the NASA Form 1612, Contract Closeout Checklist
STRENGTH:
SSC AMO has done a tremendous job improving the quality of Simplified Acquisitions. Work instruction SWI-5100-0003 has been instrumental in improving file consistency and completeness.
CONSIDERATIONS:
(1) It is recommended that the SSC Procurement Officer stress the importance of substantiating price reasonableness determinations with supporting file documentation. Also, in cases where GSA schedules are utilized, encourage specialists to go beyond GSA schedule pricing and seek additional discounts from schedule contractors.
(2) It is recommended that the Procurement Officer stress the importance of complete file documentation, including required forms and certifications, in particular NF 1707 certifications.
3. Interagency Agreements:
Four interagency agreements were reviewed as part of the survey. One was the result of a CAN and the other three were stand alone actions. All of the files contained the required D&F meeting all of the requirements identified in FAR 17.503, but none of the D&Fs included the period of performance or whether the action was a follow-on for the same services from the same agency as required by NFS 1817.7002 (c). Additionally, none of the D&Fs contained in the files were reviewed by the SSC legal office before execution as required by NFS 1801.770.
NFS 1817.7002 (b) states, “Current market prices, recent acquisition prices, or prices obtained by informational submissions as provided in FAR 15.201 may be used to ascertain whether the acquisition can be accomplished more economically from commercial sources.” Although all files reviewed contained the language, “the services cannot be obtained as conveniently or economically by contracting directly with a private source,” there was no documentation to show why the procurements could not be accomplished more economically from commercial sources.
WEAKNESS:
The assertion that services cannot be accomplished more economically by the private sector should be supported by a brief description of how that fact was ascertained. (Repeat Finding)
CONSIDERATION:
Management should insure all D&Fs are coordinated with the legal office and the D&Fs meet all the content requirements of NFS 1817.7002.
4. Bank Card Program:
There are currently 31 active NASA Purchase card (P-card) holders. There is an Agency –Organization Program Coordinator (A-OPC) and a Contractor employee who monitor the P-card process. The A-OPC and the Contractor employee appear to both be well informed about what is considered inherently governmental and the appropriate duties of each concerning the monitoring and administering of the P-card system.
The SSC Procurement Officer issues a delegation to the cardholders with their limits of authority. There is a $2500 per transaction limit and a $25,000 per month limit. There are two exceptions to the limits. One employee in the Training Office has a $25,000 per transaction limit and a $75,000 per month limit; two employees in the AMO have a $100,000 per transaction limit and a $1M per month limit. SSC is in the process of increasing the limits for the personnel within the AMO.
The cardholders and approving officials are required to be recertified every three (3) years. The two required training courses are both offered on-line. The two training courses are the IEM 1035 Bankcard Desktop and Receiving Training and the NASA P-card Program, which requires taking a test. The final requirement for a new cardholder is to meet in person with the A-OPC to go over the work instructions, i.e. what can and cannot be purchased. Each of the P-card holders has an Approving Official and an Alternate Approving Official in the event one of them is unavailable.
There is a quarterly audit report that is generated by the A-OPC, which identifies each transaction. In the Quarterly Bankcard Program Audits, there are five functions that are audited for 100% of the P-card purchases. The functions are procurement, finance, information technology, property, environmental, and safety. Each of the areas are reviewed to ensure that each of the P-card purchases have proper concurrence such as a ladder must have concurrence from the Safety Office, new software needs concurrence from the IT Department, hazardous materials must have concurrence from the Environmental Office, etc. In the quarterly P-card audits, the Environmental Auditor verifies that: 1) required recycled products are being purchased such as printer and ink cartridges, office supplies made of plastic, concrete, etc.; 2) if hazardous materials were purchased with the P-card, that all the necessary concurrences were received prior to purchasing. The Environmental Auditor also checks to verify that required recycled products are being purchased such as printer and ink cartridges, office supplies made of plastic, concrete, etc. The A-OPC and representatives from four other functions review each transaction to make sure there are no improper purchases such as food or food- related items. He also checks for split purchases, which occur when a cardholder is trying to purchase over their $2,500 per transaction limit.
When asked if P-cards are returned if unused for a period of time, it was explained that most offices maintain a P-card holder in the event of an emergency.
A recent audit disclosed an instance where a card was used improperly for purchasing forks, knives and spoons. This particular user was advised that this type of acquisition is not an appropriate use of the bankcard.
STRENGTH:
It appears that the Bankcard/P-Card Program is being performed in an exemplary manner. All the documents were organized and the process was well understood by the A-OPC and the P-card Processing personnel. It appears that the process is being well implemented and documented and the A-OPC and P-card personnel are proactive in expeditiously rectifying and processing monthly statements for prompt payment. The quarterly P-card audits covering 100% of the purchases are also seen as an effective way to ensure that the P-cards are used properly.
CONSIDERATIONS:
It is suggested that the A-OPC review P-Card usage to determine if the P-cards are infrequently used, and if so, the cards should be removed from the system unless a mechanism is established to retain P-cards for emergencies.
5. Self-Assessment:
The team reviewed SSC AMO’s self-assessment program to ensure the Center was in compliance with the Agency Self-Assessment Guide, and was focusing on areas in need of improvement. The SSC AMO has been conducting assessments in accordance with the procedures outlined in the NASA Self-Assessment Guide since the last survey. However, the period from October 2004 through September 2005 was not conducted within the prescribed semi-annual timeframe due to the transition of a new Procurement Officer, staff turnover and Hurricane impact. Rather than ignoring the missed periods, SSC AMO actually went back and performed an in-depth analysis for the omitted periods as well completing Phase 1 of the current assessment. The Phase 1 most recent self-assessment will become final once the affected procurement staff has had an opportunity to respond to the identified findings. Review topics for the self-assessment mirrored some topics that had been identified in the last SSC AMO procurement survey report conducted in CY 2002 and a significant number of topics were initiated by the Center. The report was well organized that included the purpose, findings, overall assessment and how to handle corrective actions.
STRENGTH:
The SSC Procurement Officer is commended for having the resolve to go back and randomly review contract files, simplified acquisitions, agreements, and other procurement functional areas to get a better historical grasp of the end products and not use transition, lack of staffing and Katrina as rationale for non-compliance.
CONSIDERATIONS:
(1) It is recommended that all self-assessment areas in need of improvement be highlighted and focused on to avoid repeat findings in those areas. The areas of improvement may be analyzed as part of the standard document review process.
(2) The SSC Procurement Officer should identify the percentage of reviewed actions by category where applicable in future self-assessments.
6. Construction Contracts:
A total of seven construction contracts were reviewed to determine the level of compliance with the aforementioned regulations and policy guidance directives. The survey team found that SSC is accomplishing these activities in a manner consistent with the regulations. The Survey Team found SSC used these rules correctly and consistently. In particular the construction contracts observed were found to be well documented, organized, very thorough and professional, compliant with NASA policy, and in compliance with the FAR. The following is a partial list of the items reviewed and observed in the files.
STRENGTH:
SSC AMO is commended for the overall high quality observed in the construction contract files reviewed. More specifically, the efforts of Jason Edge should be commended. He does outstanding work and has outstanding files.
7. Environmental Issues:
The survey team reviewed five contracts for the inclusion of required environmental clauses. There was no evidence that any of the files involved acquisitions of EPA-designated products not meeting applicable minimum recovered material content recommended by EPA guidelines.
In order to ensure that the NASA Purchase-card (P-card) holders are meeting the requirements of PIC 01-27, the Agency-Organization Program Coordinator and the Environmental Auditor hold annual Affirmative Procurement Awareness Program training to all cardholders.
STRENGTH:
The A-OPS and the Environmental Auditor offer annual “Affirmative Procurement Awareness Program” training to all P-card holders.
CONSIDERATION:
The SSC Procurement Officer should ensure any contracts with possible Affirmative Procurement implications are documented in accordance with PIC 01-27.
8. Internal Policies and Procedures:
The SSC AMO maintains the SSC Procurement Portal that contains links in four major categories: Applications; Programs; Procedures and Procurement Tools and Why, What, When and Where. The Applications section contains links to sites such as Consolidated Contracting Initiative (CCI), NASA Acquisition Internet Service (NAIS), Past Performance Database (PPDB), etc. It is noted that the link to one site in this area is no longer valid – Financial and Contractual Status System (FACS). This site was changed to NASA Procurement Management System (NPMS) in February 2003. The Programs section contains links to sites such as GSA Advantage, SEWP III, ISO 9001 Work Instructions, etc. The link to the Stennis Purchase Card Program is no longer valid. The Procedures and Procurement Tools section contains links to sites such as Central Contractor Registration (CCR), FAR, NASA Procurement Library, etc. The link to the FAR site was changed by GSA within the last year and the SBA 8a Contractor search site was closed, since SBA now relies exclusively on the CCR for that information. The Why, What, When and Where section contains links to various phone directories and organization charts. The link to the Postal Service Zip Code search is no longer valid. It is noted that the Procurement Portal website was last updated on June 15, 2005.
The Stennis ISO 9001 Work Instructions webpage includes instructions for the following areas: Procedures for Purchase Card Holders; CPAF Performance Evaluation Boards Charter; SSC Procedures for Initiating the Purchase of Supplies and Services; Master Records Index for the Acquisition Management Office; Purchasing Instructions; Documentation of Simplified Acquisitions; Contractor Past Performance for Contracts Exceeding $100,000; Procedures for Review and Approval of Procurement Documents; Issuance of SSC Office of Procurement Work Instructions.
CONSIDERATION:
The SSC Procurement Officer should ensure that links are accurate and that discontinued links are updated so that the accurate information is accessible at all times. The Procurement Officer should consider including links to sites such as the Past Performance Information Retrieval System (PPIRS) (that include government-wide information on contractor performance for all contracts including construction and architect and engineering) and direct links to NASA Procurement Information Circulars (PICS) and Procurement Notices (PNs). Links to the latter two sites may be accessed through the NASA Procurement Library, however, direct links may be more useful to working level contracting officers and specialists.
9. Contracting Actions Resulting from Katrina:
The team reviewed a large sampling of contractual vehicles and internal documents that were identified as being used in support of Katrina recovery at SSC. The files were documented indicating that the work was performed in support of Hurricane Katrina aftermath. SSC is commended for establishing a “Green Book” that initially recorded all needed emergency procurement activities and discussions with Headquarters in the wake of Hurricane Katrina. Jim Huk and Jason Edge in the SSC AMO deserve high honors in spite of personal loss and heartache to stay on-site at SSC to execute the “Green Book” emergency activities in the best interest of the Agency. SSC had the GSFC detailed contract specialist to perform an independent analysis of the “Green Book” to ensure the recordings were as accurate as possible prior officially documenting the files. Subsequently, contract and purchase order files were officially documented for the record. In a time of emergency, SSC is to be commended for providing invaluable support to the affected Gulf Region.
STRENGTHS:
(1) The SSC Procurement Officer and staff are commended for officially documenting the “Green Book” Katrina related emergency procurement activities in a timely manner.
(2) Jim Huk and Jason Edge demonstrated the call of duty beyond normal expectations to support Hurricane Katrina recovery at SSC. Thanks to their dedication, SSC can share valuable lessons learned with the Agency.
(3) The SSC Procurement Officer and staff are commended for ensuring that the Mississippi Space Services (MSS) subcontract consent files are documented for all Katrina related procurements.
(4) The SSC Procurement Office is commended for coordinating administrative activities such as insurance coverage and administrative leave promptly with its contractors without interruption for vital services.
10. Contracts for Administrative or Office Support:
The contract files reviewed contained a Conflict of Interest Plan, Management Operating Plan, Safety Plan and Surveillance Plan.
The files contained the appropriate NASA Form 1634, Contracting Officer Technical Representative/Alternate COTR Delegation, and both a COTR and Alternate COTR have been appointed and have accepted the delegations. However, in one of the files, the delegation for the Alternate COTR was signed, but not dated by the Alternate COTR. It was noted that the COTR and Alternate COTR received alternate training in lieu of COTR training until they were able to take the COTR training with the Procurement Officer’s approval.
The FPDS-NG document states that the Contractor is required to submit NASA Form 533M and 533Q reports, but the contract was a firm-fixed priced contract. However, since no NF-533 reports were being submitted this was most likely improperly checked in FPDS-NG.
11. Commercial Acquisition:
The Survey Team reviewed five commercial acquisitions for adherence to FAR Part 12 requirements. All files reviewed were complete and adequately documented. Files showed outstanding market research. Files were well organized. All appropriate clauses and conditions were well thought out and complete.
STRENGTH:
The AMO should be commended for exemplary file documentation with well thought out and complete clauses and conditions.
12. Small Business Innovative Resources (SBIR) Awards:
The Survey Team reviewed three SBIR Phase II contracts. All files reviewed were complete and adequately documented. Files were well organized. All appropriate clauses and conditions were well thought out and complete.
13. Metrics:
The SSC AMO collects metrics in the areas of small business goals, lead times, ULOs, UCAs, and timeliness of award fee payments. In the past these metrics were reported to the SSC Integrated Management Counsel. However due to changes in center management, the requirement to report these metrics at that level has not been reinstituted. In the future the Procurement Officer will report the metrics at that level with a Green, Yellow, and Red scoring to show how well the AMO is performing. However, some metrics are reported on the N-Drive, an internal Center Management shared drive. Also, the Procurement Officer is currently developing a questionnaire to send out to customers to determine the level of satisfaction the customers have with the AMO.
1. Organization and Staffing:
The SSC Small Business Program is currently assigned to the Policy and Pricing Branch of the Acquisition Management Office (AMO). The SSC Small Business Office consists of one person serving as the Small Business Specialist (SBS). The Procurement Officer (PO) is currently working to reorganize the office to realign personnel to cover losses in significant areas. The draft organization chart reorganizes the Small Business Program under a newly established branch titled Procurement Management Support Division. In addition to Small Business, this branch will encompass the following functions: SAP/CMM; Data Calls/Reports/Metrics; Policy; Pricing; Training; Self Assessments; and Procurement Management Surveys. The SBS will be required to work these other areas as necessary. The expectation is that the SBS will spend at least 60 percent of time on small business issues.
STRENGTH:
The SBS receives full support from the PO. The PO acknowledges that there is work that would allow the SBS to devote full time to small business issues; however, limited funding (e.g. $13,700 of travel dollars for all of procurement) and staff prevents this. The PO has lost a number of staff through attrition, death and transfers. As a solution, the PO has requested permission to hire an intern from the Federal Career Intern Program to provide support to the new branch. This new hire will be able to dedicate some time in support of the SBS.
CONSIDERATION:
The SBS has been on board since February 2006. The SBS did not have a transition period with the previous SBS. Further, the SBS has a strong procurement background but does not have small business experience or familiarity with NASA’s organization and operation; therefore, the SBS is experiencing a significant learning curve. The Assistant Administrator (AA) for the Office of Small and Disadvantaged Business Utilization (OSDBU) should consider identifying training that provides the information and guidance to assist an SBS in performing the job. Although each Center has its own culture, there are functions that are identical across all centers so it would be beneficial for this training to be mandatory for all new specialists.
2. Outreach:
The SBS was recently hired in February 2006 and was permitted to attend the annual JPL High Tech Conference in March 2006. This is a key conference because it is the largest conference hosted by the OSDBU, all NASA centers’ SBSs are present, and the OSDBU conducts its Prime Contractors roundtable. During this conference, the SBSs are required to work the marketplace which gives them first hand experience with one-on-one counseling. The PO encourages the SBS’s participation at significant State sponsored conferences such as the recurring conference that is hosted by the State of Louisiana, and the SBA conference that is held each June. The PO has proposed to the Center Director, and received concurrence, to establish a prime contractors’ forum similar to what’s done at other centers. Additionally, the PO and SBS are also looking to partner with the Mississippi Support Services (MSS) (contractor providing base support operations) where SSC will serve as host to their quarterly conference. This conference targets traditionally non high tech small businesses whose services are critical to the operation of the Center.
Three small businesses (ERC, AGT, and Holiday Construction) were interviewed to ascertain the support they are receiving from the small business office. Collectively, these businesses have been nominated and won various awards: the 2005 George M. Low Award for Small Business of the Year in a service category, SBA’s Small Business Person of the Year Award for State and Regional, 2005; various Contractor of the Year Awards for the State, and one contractor is currently in NASA’s Mentor-Protégé Program.
STRENGTH:
The SBS should be commended for successfully maintaining the positive working relationship with the contractors that was set by previous SBSs. The contractors stated they were informed of the various NASA-sponsored programs that target small businesses and have participated in and benefited from several of the programs. They especially appreciated the open door policy with both the Small Business and Procurement Offices. A goal of the OSDBU is to ensure that small businesses, both inside and outside of NASA, are knowledgeable of the various programs available to them, and they know how to avail themselves of those programs. This goal is clearly being achieved.
3. Goal Achievement:
Percentage of Total FY06 Obligations Awarded to Small Business as of 05/31/06:
| Category | Goal | Actual |
|---|---|---|
20.0 |
7.4 |
|
FY06 had a slow start due to the effects of Hurricane Katrina. There is $7M in small business awards not reflected in these numbers. The AMO staff was reduced to less than half, and as a result, several purchases were made through the Facility Operations Services (FOS) contractor - MSS.
Percentage of Total FY05 Obligations Awarded to Small Businesses:
| Category | Goal | Actual |
|---|---|---|
22.9 |
17.7 |
|
Discrepancies with the FPDS-NG system continued in FY05. SSC believes that these discrepancies have resulted in an understatement of several categories of awards. SSC also states that they did not meet their FY05 Small Business and Woman owned goals because:
CONSIDERATION:
Since the Center believes that they have not met their FY05 goals because of system problems with FPDS-NG, the SBS and Procurement staff should continue reconciling their FY05 data with FPDS-NG to make sure all of their information has been captured in the government-wide system. The Procurement staff is able to access FPDS-NG to make adjustments or corrections. If system problems continue, the SBS or Procurement staff should notify the FPDS-NG manager at Headquarters to get the problems resolved.
4. SBIR/STTR:
SSC has an active SBIR/STTR program. There are small businesses on Center who have come through the SBIR/STTR program. Twice a year, the University of Mississippi hosts a SBIR conference to discuss NASA’s SBIR program. The SSC SBIR Program Manager is an active participant in these conferences. These conferences draw small businesses from across the country.
5. Small Business Technical Advisor (SBTA):
This function has been assigned to the SBIR/STTR program manager. Although the program manager has received a copy of the document titled, “Expectations of the NASA OSDBU on the Practices of Center Small Business Technical Advisors”, which details what would be expected of a person working effectively in this position, it does not specifically describe the duties of the position. The program manager does not understand his role in promoting small businesses at his Center or how he should work with the SBS in accomplishing this mission.
WEAKNESS:
The Center was cited in the 2002 survey for not having a person assigned the responsibility of SBTA. Although someone has been assigned, the assignment was recent (approximately April 2006). Prior to this recent assignment, the current incumbent’s supervisor was delegated this responsibility; however, the current incumbent is unaware of his responsibilities.
RECOMMENDATION:
The SSC SBTA should discuss with his supervisor the objectives of the position. He should also contact other SBTAs across the Agency to determine how they fulfill their role at their individual centers.
6. Small Business Administration (SBA) Procurement Center Representative (PCR):
There is not a PCR that is dedicated to supporting the SSC. There is a SBA PCR available to answer questions from NASA, as well as from small businesses with questions or issues relative to NASA; however, according to the SBA PCR, an agreement is required for SBA to provide full support to NASA. Full support includes reviewing NASA’s small business program for determination on small business set asides.
CONSIDERATION:
NASA AA for the OSDBU should initiate the necessary MOU to allow SSC to receive full support from the SBA.
7. HBCU/OMEIs:
Currently, the Center has two HBCUs:
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