Summary of GSFC 2011 Procurement Management Review (PMR) Findings March 6, 2014 Jim Becker.

Summary of GSFC 2011 Procurement Management Review

(PMR) Findings

March 6, 2014Jim Becker

Presentation Objectives

• Provide summary of findings and actions taken since June 2011 PMR

• Identify certain areas where we may improve through future focused training, including future All Hands Meetings

PMR STRENGTHS

Communications/Knowledge SharingEmployee Learning/Working Groups*Procurement Website and Knowledge Sharing Activities

Career Development/TrainingDivision Training Plan, in-house training courses, Master’s Forum, FAC-C/Career Development tracking

PMR STRENGTHSProcess/Documentation

Procurement Strategy Meeting (PSM) and file documentation on large-dollar actionsSelection process and documentation in high-dollar value, high-visibility procurements*Cost/Price analysis in high-dollar value, high-visibility procurements*Use of Preneg Position Memo (PPM) and Post-Negotiation Memo (PNM) templates

PMR STRENGTHSProcess/Documentation (Cont’d)

Industrial Property Officer (IPO) document review process

Reporting/Management/Tracking Contracting Officer’s Representative (COR) training/certification trackingManagement of Purchase Card Program

PMR STRENGTHS

Reporting/Management/Tracking (Cont’d) • Closeout Initiative/Reduction in Closeout

backlog• Use of Unliquidated Obligations (ULO)

Analysis System for closeouts

PMR WEAKNESSESProcess/Documentation

Surveillance Plans not in file as required by NFS 1837.604 and surveillance activities not documented as required by FAR 46.401**

Action: Procurement Online Weekly (POW) reminder sent to 210 workforce on 6/8/12. New PMR review checklist being developed.

COR Delegation Forms (NF1634) not in file as required by NFS 1842.270

Action: POW reminder sent to 210 workforce on 5/25/12. Add to new PMR review checklist.

PMR WeaknessesProcess/Documentation (Cont’d)

Determination of need for “special” surveillance for actions above $1M not in file as required by NFS 1844.201-1**

Action: POW reminder sent to 210 workforce 6/7/12. Add to new PMR review checklist.

5yr Deviation in non-competitive, follow-on IAAs not executed IAW NFS 1817.7001

Action: POW reminder sent to 210 All on 6/8/12. GSFC circular 99-3 modified to include deviation requirement. Add to new review checklist. (Note: Review level is Center Director for actions $5M or less, Assistant Administrator for actions greater than $5M.)

PMR WEAKNESSESProcess/Documentation (Cont’d)

Inadequate or missing cost/price analysis and supporting rationale in low dollar actions IAW FAR 15.4 and NFS 1815.4*

Action: Developed new “Documenting Negotiations” training for procurement and technical personnel. Training starts 3/11/14, then plan is to conduct 2X/year.

Requirements in FAR 17.207 and NFS 1817.207 not addressed when exercising options*

Action: Training package for options posted to Procurement website on 5/10/12; training “open house” conducted on 11/7/13. Office-level training also conducted in 210.S and 210.M.

PMR WEAKNESSESProcess/Documentation (Cont’d)

Analysis of 533M and 533Q reports not documented* Action: 533 Analysis Training rolled out to 3 offices 210.M, 210.H, and 210.Y to date; subsequent training to be conducted.

Documents not generated in CMM/PRISM and don’t match what is posted to NAIS/EPS.

Action: POW sent out to 210 All on 6/8/12 re: procurement actions should be generated in CMM/PRISM and should match what is posted to NAIS/EPS.

PMR WeaknessesProcess/Documentation (Cont’d)

File documentation incomplete, missing, or not compliant with FAR Part 13 procedures in Simplified Acquisition awards and modifications*

Action: Simplified File Checklist now used; Issues continued to be discussed at monthly SPAT meetings.

Task and Delivery Orders not generated in CMM/PRISM

Action: Currently under review by the Management Team

PMR WEAKNESSESProcess/Documentation (Cont’d)

Purchase Orders using credit card for payment did not include written documentation.

Action: Email sent 3/28/12 to all P-Card holders and COs that issue POs, reminding them of FAR requirements for written documentation when utilizing the P-card for payment.

Untimely CPARs and AFES contractor performance reporting*Action: Training conducted in March 2012 on CPARs process, including FAQs and instructions; training package posted to 210 website; monthly summary CPARs reports provided to Division Managers with due dates. Refresher training to be conducted.

PMR RECOMMENDATIONSCommunications/Knowledge Sharing

Providing rationale/progress updates to customers during procurement process.

Action: Customer satisfaction assessed again during Self Assessments and upcoming PMR

Process/DocumentationProviding quality documents to Legal for review

Action: POW reminder sent to 210 ALL on 5/25/12, including a reminder to include disposition of reviewer comments from prior reviews in file.

PMR RECOMMENDATIONS

Process/DocumentationDeterminations for the need for Contractor Purchase System Reviews (CPSRs) not being made IAW FAR 44.302, and documenting of Purchasing System approvals not in file.

Action: POW reminder sent to 210 workforce 12/27/12. Add to new review checklist.

Tech Evals not completed IAW NFS 1815.404-1, including analysis and rationale for acceptance of costs.

Action: Developed new “Documenting Negotiations” training for procurement personnel. Training on-going.

PMR RECOMMENDATIONSProcess/Documentation (Cont’d)

Correct CMM/PRISM PR Milestone Template not used

Action: Training on Milestone Plan creation/completion conducted on 6/2012. “Open House” training also conducted on 11/7/13.

Fee rationale not documented on NF-634 IAW NFS 1815.404-470

Action: Documenting rationale included in new “Documenting Negotiations” training. Training on-going.

PMR RECOMMENDATIONSTimeliness

Take initiative to definitize UCAs and Letter Contracts within goal of 180 days IAW NFS 1843.7005 and FAR 16.603-2

Action: UCAs and Letter Contract actions now tracked at Center Director Mgt level in both weekly and monthly reports.

PMR ConsiderationsProcess/Documentation

Consider providing rationale for awarding phase-in periods as separate contracts actionsConsider utilizing DCMA for certain limited administration activities, such as making CPSR determinations and conducting CPSRs.Consider wider use of GSFC Form 210-49 to document 533 analysis

PMR ConsiderationsTimeliness

Take initiative to decrease lead-times on competitive actions

GSFC participation on HQs Procurement Lead-time Team

Small Business (SB) PMR Findings - Strengths

Good Relationships between Small Business Specialist (SBS) and Procurement, the Procurement Center Representative (PCR), and Small Business Technical Advisor (SBTA)High Percentage of Set-Asides on Competitive ProcurementsGood Template for Subcontracting Plan ConcurrenceTimely acceptance of Contractor Individual Subcontract Reports (ISRs)

SB PMR Findings - WeaknessesSubcontract Plans not included in some awarded contracts IAW FAR 19.702

In the two instances where plans were inadvertently omitted, contracts were modified to add the plans into the contracts

Little or no Industry Assistance Office participation in Award Fee (AF) Determinations

IAO has identified all AF contracts with Large Businesses and when each AF period ends in order to ensure subcontract plan evaluation input is provided by the IAO to Contract Specialists

SB PMR Findings - Weaknesses

AF Evaluation Plans did not include a “significant” evaluation weighting of Contractor performance against the subcontract plan IAW NFS 1816.405-274

Current plan is to implement, as appropriate, either a separate factor weighted at 10%, or a separate subfactor, if weighted less than 10%

SB PMR Findings - RecommendationsNo indication that the SBS attended Procurement Strategy Meeting (PSM) under two actions

COs need to be reminded that IAO representatives need to be invited to PSMs; SBS attendee needs to sign PSM Attendance Sheet

Contract Files inconsistent with regard to proper coordination/signature on NF 1787s from the SBS and PCR

Subject coordination now covered in SB specialist training program; IAO procedures updated to reflect that the SBS will forward documentation with PCR coordination to contract specialists

SB PMR Findings - RecommendationsContract files not documented to indicate review of subcontract plans by the SBA Procurement Center Representative (PCR) IAW FAR 19.705-4

Process developed where SBS sends PCR plan and a review/concurrence sheet; when PCR concurrence is received, SBS sends plan and review sheet to Contract Specialist to include in contract file

SB PMR Findings - Considerations

Consider including evaluations of subcontracting achievements in past performance information inputted into CPARS

Questions?

Copy of Full 2011 Procurement Management Report available on 210 Procurement website, “Div and Policies” tab