oversight

Contract Management: No Reliable Data to Measure Benefits of the Simplified Acquisition Test Program

Published by the Government Accountability Office on 2003-09-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to Congressional Committees




September 2003
                 CONTRACT
                 MANAGEMENT
                 No Reliable Data to
                 Measure Benefits of
                 the Simplified
                 Acquisition Test
                 Program




GAO-03-1068 

                                                September 2003


                                                CONTRACT MANAGEMENT

                                                No Reliable Data to Measure Benefits of
Highlights of GAO-03-1068, a report to the      the Simplified Acquisition Test Program
Senate and House Committees on Armed
Services




In recent years, the federal                    Because the Federal Procurement Data System contains unreliable data
government has introduced new                   about the simplified acquisition test program, GAO was unable to determine
ways to streamline the acquisition              the extent to which federal executive agencies—including DOD— have used
process. One of those vehicles is               the test program and have realized any benefits. Specifically, the database
the simplified acquisition                      indicated that the Departments of Treasury, Defense, and Justice were the
procedures test program, which
removes some of the procedural
                                                three largest dollar-value users of the test program in fiscal year 2001 (the
requirements for buying                         latest year with complete data available). But GAO found that FPDS either
commercial goods and services.                  overstated or understated use of the test program by millions of dollars. The
Using the test program, federal                 table below shows examples of discrepancies at different buying
procurement officials can make                  organizations within these three departments.
purchases faster than they have in
the past for procurements not                   Examples of Discrepancies with FPDS’s Data
exceeding $5 million.                                                     Value of test program
                                                 Department’s            contracts, according to    What procurement officials said about
Congress mandated that GAO                       buying organization     FPDS (fiscal year 2001)    FPDS’s data
determine the extent to which                    Department of the                   $242 million   U.S. Mint said it did not use the test

federal executive agencies—at a                  Treasury’s U.S. Mint                               program at all 

                                                 DOD’s Defense                         $4 million   Defense Logistics Agency said it obligated 

minimum, the Department of                       Logistics Agency                                   $146 million in test program contracts

Defense (DOD)—have taken                         Department of                       $118 million   After reviewing portions of FPDS data, 

advantage of the test program and                Justice’s Federal                                  about $31 million in contract actions,

any benefits realized. One way to                Prison Industries                                  Federal Prison Industries said none of 

measure use is to examine test                                                                      those items were purchased under the test
program data from the Federal                                                                       program
Procurement Data System (FPDS).                 Sources: FPDS (data); GAO (analysis).

It is the central repository of
contracting information. In                     GAO also found data reliability problems with contract data in DOD’s own
addition to examining FPDS data,                data system—the Defense Contract Action Data System (DCADS)—which
GAO looked at data from DOD’s                   feeds into FPDS on an ongoing basis. For example, for fiscal year 2002,
data system.                                    DCADS showed about $146 million in test program contract actions for two
                                                buying organizations for the Naval Air Systems Command and the Defense
                                                Intelligence Agency. After reviewing contract actions that had the highest
Before Congress decides whether                 dollar value, procurement officials at these two DOD buying organizations
to make the test program a                      said that none of the entries were awarded through the test program. There
permanent contracting vehicle,                  were also reliability problems at other buying commands.
GAO recommends that DOD and
other selected federal executive                The federal buying organizations we visited have not collected any other
agencies ensure that reliable data              data that would allow us to assess whether the test program is helping to
are available to make program
                                                increase efficiency, improve contract prices, reduce administrative costs, or
assessments. DOD agreed with
GAO’s recommendation, while the                 improve the delivery of goods and services. Anecdotal evidence indicates
other selected federal agencies had             that the test program is getting favorable reviews. For example, nearly all
no comments on the                              procurement officials with whom GAO spoke at the buying organizations
recommendation.                                 GAO visited indicated that the program’s primary benefit is the ability to
                                                process a contract more efficiently.
www.gao.gov/cgi-bin/getrpt?GAO-GAO-03­
1068.

To view the full product, including the scope
and methodology, click on the link above.
For more information, contact David Cooper
at (202) 512-4125 or cooperd@gao.gov.
Contents 



Letter                                                                                                     1
                Results in Brief                                                                           2
                Background                                                                                 2
                No Reliable Data Available to Assess Test Program                                          4
                Conclusion                                                                                 6
                Recommendations for Executive Action                                                       7
                Agency Comments                                                                            7

Appendix I      Scope and Methodology                                                                      9



Appendix II 	   Comments from Department of Justice’s Federal
                Bureau of Prisons                                                                         10



Table
                Table 1: Examples of Discrepancies with FPDS’s Data                                        5




                Abbreviations

                DCADS             Defense Contract Action Data System 

                DOD               Department of Defense 

                FAR               Federal Acquisition Regulation 

                FPDS              Federal Procurement Data System 

                GAO               General Accounting Office 

                OFPP              Office of Federal Procurement Policy 


                This is a work of the U.S. government and is not subject to copyright protection in the
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                Page i                               GAO-03-1068 Simplified Acquisition Test Procedures
United States General Accounting Office
Washington, DC 20548




                                   September 30, 2003 


                                   The Honorable John W. Warner 

                                   Chairman 

                                   The Honorable Carl Levin 

                                   Ranking Minority Member 

                                   Committee on Armed Services 

                                   United States Senate 


                                   The Honorable Duncan Hunter 

                                   Chairman 

                                   The Honorable Ike Skelton 

                                   Ranking Minority Member 

                                   Committee on Armed Services 

                                   House of Representatives 


                                   Acquisition reform has fundamentally changed the way the federal 

                                   government procures billions of dollars worth of goods and services each

                                   year. The procurement process is more streamlined than ever before. 

                                   Government buyers can make their purchases with less turnaround time, 

                                   they have less paperwork, and they can rely on a variety of tools to help 

                                   them expedite the process. One tool is the simplified acquisition 

                                   procedures test program, which reduces the procedural requirements for 

                                   buying commercial goods and services not exceeding $5 million. 


                                   Congress mandated that we report on the test program and address the (1) 

                                   extent to which federal executive agencies—at a minimum, the 

                                   Department of Defense (DOD)—have used the test program, (2) benefits 

                                   realized through its use, and (3) impact that the program has had on 

                                   contract competition.1


                                   To satisfy these objectives, we obtained and analyzed test program data 

                                   from the Federal Procurement Data System (FPDS) and DOD’s Defense 

                                   Contract Action Data System (DCADS). We used these data to identify 

                                   buying organizations that were among the largest total-dollar-value users 

                                   of the test program and to review contract files at selected buying 




                                   1
                                    Our reporting mandate is found in the Bob Stump National Defense Authorization Act for
                                   Fiscal Year 2003, Pub. L. No. 107-314, sec. 812, Dec. 2, 2002.



                                   Page 1                              GAO-03-1068 Simplified Acquisition Test Procedures
                   organizations to determine the accuracy of the data reported. We
                   interviewed procurement officials to determine whether use of the test
                   program has resulted in noticeable benefits or affected competition.


                   Because the FPDS and DCADS databases contain unreliable test program
Results in Brief   data, we were unable to determine the extent to which federal executive
                   agencies, including DOD, have taken advantage of the program. Neither
                   were we able to determine the test program’s benefits and impact on
                   competition.

                   The federal buying organizations we visited have not collected any other
                   data that would allow us to assess whether the test program is helping to
                   increase efficiency, improve contract prices, reduce administrative costs,
                   or improve the delivery of goods and services. Two years ago, we reported
                   that data were not being collected to provide a basis for measuring
                   whether the test program produced the desired results of maximizing
                   efficiency and economy and minimizing administrative burden and cost.
                   We recommended that data be collected to demonstrate the benefits of the
                   test program. In response to our recommendation, DOD said it planned to
                   convene an integrated process team to determine ways to measure the
                   benefits of the test program. However, DOD has not taken action to
                   measure the program’s benefits.

                   This report recommends that DOD and the Office of Federal Procurement
                   Policy (OFPP) develop evaluation mechanisms for measuring test program
                   benefits. It also recommends that the Departments of Treasury, Justice,
                   and Defense improve the reliability of test program data to make program
                   assessments. DOD partially concurred with the first recommendation and
                   agreed with the second. The other two federal executive agencies had no
                   comments on our recommendations.


                   To streamline the federal procurement process, Congress in 1994
Background         authorized the use of simplified acquisition procedures for purchases not
                   exceeding $100,000.2 Simplified procedures allow agency officials to
                   expedite the evaluation and selection processes and keep documentation
                   to a minimum.




                   2
                       Federal Acquisition Streamlining Act of 1994, Pub. L. No. 103-355, Oct. 13, 1994.




                   Page 2                                   GAO-03-1068 Simplified Acquisition Test Procedures
In 1996, Congress expanded the use of simplified acquisition procedures3
by authorizing a test program that allows government buyers to procure
commercial items not exceeding $5 million4 in order to maximize
efficiency and economy and minimize burden and administrative costs for
both the government and industry.5 For example, government buyers

•	  may issue a combined synopsis and solicitation and may require
    proposal submission in fewer than 45 days, as would otherwise be
    required;
• 	 need not establish a formal evaluation plan or competitive range,
    conduct discussions with vendors, or score quotations or offers; and
• 	 can minimize the documentation required to justify contract award
    decisions.

Under simplified acquisition procedures, the Federal Acquisition
Regulation (FAR) requires competition to the maximum extent
practicable.6

The test program, which expires on January 1, 2004, is only one of a
number of streamlined contracting vehicles that federal agencies use to
procure goods and services. Other options include purchase cards,
multiple award Federal Supply Schedule contracts, governmentwide
acquisition contracts, and multiple award task and delivery order
contracts. In one way or another, these options allow government buyers
to simplify and expedite the procurement process.

In 2001, to find out whether the test program was achieving desired
results, we evaluated DOD’s use of the program for commercial




3
  Clinger-Cohen Act of 1996, Pub. L. No. 104-106, Div. D, Feb. 10, 1996 (short title changed
from Federal Acquisition Reform Act of 1996 to Clinger-Cohen Act of 1996, Pub. L. No. 104-
208, sec. 808, Sept. 30, 1996).
4
    Federal Acquisition Regulation, Subpart 13.5.
5
 Since then, there has been another effort to simplify procurement in special situations.
The Homeland Security Act of 2002 temporarily expands the use of simplified acquisition
procedures (Pub. L. No. 107-296, sec. 855(b), Nov. 25, 2002). The act authorizes executive
agencies to use simplified procedures in any procurement of property or services acquired
as part of the fight against terrorism and related threats.
6
    FAR sec. 13.104.




Page 3                                  GAO-03-1068 Simplified Acquisition Test Procedures
                      purchases.7 We reported that data had not been collected to provide a
                      basis for measuring whether the test program was maximizing efficiency
                      and economy and minimizing administrative burden and cost. However,
                      our report summarized a 1999 OFPP survey showing that procurement
                      executives believed the program improved the federal procurement
                      process and that the test program should be made permanent. We asked
                      Congress to consider requiring the OFPP to develop a method for
                      demonstrating that the test program was producing desired results.

                      FPDS is the central repository of federal contracting information, and it
                      contains detailed data on contract actions exceeding $25,000. Although
                      federal agencies collect contract data using their own data systems, their
                      data must be transmitted to and consolidated in FPDS on an ongoing
                      basis. FPDS can assist procurement managers in making such decisions as
                      understanding the consequences of their purchasing decisions, projecting
                      future needs, or leveraging overall buying power.

                      FPDS was designed to provide basic contracting information, such as
                      whether the simplified acquisition test program was used. FPDS also was
                      designed to provide insight on small business participation and
                      competition, among other things. Federal officials can use the data to
                      perform oversight responsibilities. The General Services Administration,
                      through the Federal Procurement Data Center, operates and maintains
                      FPDS. DOD accumulates similar data on contract actions of over $25,000
                      in the DCADS database, and, like other federal agencies, transmits
                      contract information to FPDS.


                      We found significant data-reporting errors related to the test program in
No Reliable Data      both FPDS’s and DCADS’s databases. Because of unreliable data, we were
Available to Assess   unable to determine the extent to which federal executive agencies have
                      used the simplified acquisition test program and what benefits they may
Test Program          have realized from its use. We also could not determine the impact that the
                      test program has had on contract competition.

                      To verify FPDS’s data, we visited the Departments of Treasury, Defense,
                      and Justice—the three largest dollar-value users of the simplified



                      7
                       U.S. General Accounting Office, Contract Management: Benefits of Simplified
                      Acquisition Test Procedures Not Clearly Demonstrated, GAO-01-517 (Washington, D.C.:
                      Apr. 20, 2001).




                      Page 4                             GAO-03-1068 Simplified Acquisition Test Procedures
acquisition test program in fiscal year 2001, as reported in FPDS. FPDS’s
data showed that the Departments of Treasury, Defense, and Justice had
test program contract actions worth about $303 million, $209 million, and
$157 million, respectively, in fiscal year 2001, the latest year with the most
complete data available. We found that these figures were either
overstated or understated by millions of dollars.

For example, as shown in table 1, FPDS’s data showed that the
Department of the Treasury’s U.S. Mint had about $242 million in test
program contract actions, making it the largest user of the test program in
fiscal year 2001. However, the U.S. Mint officials told us that they did not
use the program at all. We also found reporting errors with FPDS’s data for
DOD. An official at one of DOD’s buying commands—the Defense
Logistics Agency—said it had about $146 million in test program contract
actions, but FPDS’s data showed only $4 million. In the case of the
Department of Justice, FPDS’s data showed that the Federal Prison
Industries, which is a part of the Federal Bureau of Prisons, had about
$118 million in test program contract actions. Federal Prison Industries
officials told us they used the test program extensively, but when we
asked them to review a portion of FPDS’s data, about $31 million worth of
contract actions, they said that none of the contract actions listed were
part of the test program.

Table 1: Examples of Discrepancies with FPDS’s Data

 Department’s                            Value of test program
 buying                                 contracts, according to    What procurement officials
 organization                           FPDS (fiscal year 2001)    said about FPDS’s data
 Department of the                                 $242 million    U.S. Mint said it did not use the
 Treasury’s U.S. Mint                                              test program at all
 DOD’s Defense                                        $4 million   Defense Logistics Agency said
 Logistics Agency 	                                                it obligated $146 million in test
                                                                   program contracts
 Department of                                     $118 million    After reviewing portions of
 Justice’s Federal                                                 FPDS’s data, about $31 million
 Prison Industries                                                 in contract actions, Federal
                                                                   Prison Industries said none of
                                                                   those items were purchased
                                                                   under the test program
Sources: FPDS (data); GAO (analysis).



As with other federal agencies, DOD has its own database system to
collect contract data, and it transmits those data to FPDS on an ongoing
basis. We decided to take a closer look at DOD’s database—DCADS—for



Page 5                                        GAO-03-1068 Simplified Acquisition Test Procedures
               fiscal year 2002, the latest year with the most complete data. As we found
               with FPDS, there were reporting errors in DCADS. According to DCADS,
               DOD had a total of $1.9 billion in test program contract actions. For
               verification, we reviewed selected test program contract actions for DOD’s
               buying organizations that were major dollar-value users of the test
               program, according to DCADS. While we did find that one Air Force
               buying organization correctly reported its test program contract actions,
               other buying commands reported them incorrectly in DCADS. For
               example, DCADS’s data showed that an organization within the Naval Air
               Systems Command had about $122 million in test program contract
               actions and that the Defense Intelligence Agency’s Virginia Contracting
               Activity had $24 million. We asked procurement officials at DOD’s buying
               organizations to review DCADS’s data for contract actions that had the
               highest dollar value. They said that none of those listed were awarded
               under the test program. Three other DOD buying organizations also had
               reporting errors.

               In addition to the data reliability problems we found with FPDS’s and
               DCADS’s test program data, we also found that federal buying
               organizations had not collected any other data to document whether the
               test program is helping to increase efficiency, improve contract prices,
               reduce administrative costs, or improve the delivery of goods and services.
               However, indications are that the test program is well received. Nearly all
               procurement officials with whom we spoke at selected buying
               organizations view the test program favorably. They cite as the program’s
               primary benefit the ability to process a contract more efficiently, and the
               majority advocates making the test authority permanent.

               In commenting on our 2001 report, DOD stated its intention to convene an
               integrated process team to consider ways for measuring the benefits of the
               test program. However, DOD has not acted on this initiative.

               In discussing the results of this effort, DOD officials stated that they are
               willing to assess the benefits of the test program. Justice and Treasury
               Department officials stated that they would work to improve the reliability
               of test program’s data.


               The simplified acquisition test program, which streamlines the process for
Conclusion 	   buying commercial items that do not exceed $5 million, expires on
               January 1, 2004. Most procurement officials with whom we spoke at
               selected buying organizations said that they would like the test program to
               be made permanent and that there are benefits associated with buying


               Page 6                         GAO-03-1068 Simplified Acquisition Test Procedures
                      commercial items using simplified procedures. However, anecdotal
                      information is not enough to determine this program’s overall impact and
                      benefits. Inherent in any test program is the expectation that federal
                      agencies establish evaluation mechanisms for assessing program results,
                      which includes ensuring that reliable data are collected and used for the
                      assessments. Our observations are that there is no reliable information for
                      measuring the test program’s benefits.


                      Before Congress provides permanent authority for using simplified
Recommendations for   procedures to acquire commercial items costing up to $5 million, we
Executive Action      recommend that DOD work with the Administrator of OFPP to develop
                      evaluation mechanisms for measuring test program benefits. In addition,
                      the Departments of Treasury, Justice, and Defense should independently
                      take appropriate actions to ensure that reliable FPDS test program data
                      are available to make program assessments.


                      We asked OFPP and the Departments of Treasury, Justice, and Defense for
Agency Comments       written comments on the draft report. OMB, which oversees OFPP, and
                      DOD provided oral comments. OMB did not comment on the specifics of
                      the report but made a general observation that the test program provides a
                      benefit if used correctly. It said the test program enables agencies to gain
                      timely access to the marketplace while still reaping the benefits of open
                      market competition. OMB further noted that the test program may be
                      especially beneficial as an alternative to the Federal Supply Schedule and
                      multiple or single award task and delivery order contracts, when
                      prenegotiated terms and conditions of these vehicles are not suitable to
                      meet an agency’s needs.

                      DOD partially concurred with our recommendation that it work with
                      OFPP to develop evaluation mechanisms for measuring test program
                      benefits. DOD stated that it would develop a methodology to evaluate the
                      benefits of the test program, on the basis of such metrics as procurement
                      lead-time, and share the results with OFPP. Using this methodology, the
                      benefits of the test program would be measured by sampling test program
                      contracts from the contract reporting system. DOD concurred with our
                      recommendation that it take appropriate actions to ensure that reliable
                      FPDS test program data are available to make program assessments. DOD
                      is planning to issue a memorandum to the military departments and
                      defense agencies emphasizing the need for all test program data to be
                      entered into the contract-reporting system accurately, so reliable data are
                      available to demonstrate the continuing need for this program.


                      Page 7                         GAO-03-1068 Simplified Acquisition Test Procedures
The Department of Justice’s Federal Bureau of Prisons concurred with the
information reflected in the report; the bureau’s comments appear in
appendix II. The Department of the Treasury’s U.S. Mint agreed with our
finding that it did not use the test program.


We are sending copies of this report to other interested congressional 

committees and the Secretary of Defense; Secretary of the Air Force; 

Secretary of the Army; Secretary of the Navy; Director, Defense Logistics 

Agency; Director, Office of Management and Budget; Administrator, Office 

of Federal Procurement Policy; Administrator of General Services; 

Assistant Attorney General for Administration, Department of Justice; 

Secretary of the Treasury; and Director, U.S. Mint. We will also make 

copies available to others on request. In addition, this report will be 

available at no cost on the GAO Web site at http://www.gao.gov. 


If you have questions about this report, please contact me at (617) 788-

0500 or Ralph Dawn at (202) 512-4544. Key contributors to this assignment 

were Jeffrey Rose, Ralph Roffo, Marie Ahearn, Lily Chin, and Julia 

Kennon. 


Sincerely yours, 





David E. Cooper 

Director, Acquisition and Sourcing Management 





Page 8                        GAO-03-1068 Simplified Acquisition Test Procedures
Appendix I: Scope and Methodology 



              Our objectives were to determine the (1) extent to which federal executive
              agencies used the simplified acquisition test authority, (2) benefits they
              realized through its use, and (3) impact that the program has had on
              contract competition. To satisfy these objectives, we obtained and
              analyzed test program data from the Federal Procurement Data System
              (FPDS) and the Department of Defense’s (DOD) Defense Contract Action
              Data System (DCADS). Using the data, we identified buying organizations
              that were among the largest dollar-value users of the test program, and we
              reviewed contract files at selected buying organizations to determine the
              accuracy of the data reported. We interviewed procurement officials from
              the Office of Federal Procurement Policy and from the Departments of
              Treasury, Defense, and Justice to obtain their views of the benefits from
              using the test authority. In addition, we reviewed federal regulations and
              available test program guidance.

              We initially identified, using FPDS’s data, the major dollar-value users of
              the test program during fiscal year 2001, the year of the most recent and
              complete data we had available at the time of our review. According to the
              data, the Departments of Treasury, Defense, and Justice were the largest
              dollar-value users of the test program. We then used the data to identify
              the buying organizations within each of these departments that were the
              largest dollar-value users. We met with procurement officials at selected
              buying organizations to verify the reliability of FPDS’s test program data
              and to discuss the benefits realized.

              We also reviewed the DCADS database to respond to our congressional
              mandate’s minimum requirements. Using DCADS’s complete fiscal year
              2002 data, we selected the buying organizations within DOD commands
              that were major dollar-value users of the test authority. The selected
              organizations were the (1) Air Force Air Mobility Command, (2) Air Force
              21st Contracting Squadron, (3) Army Communications-Electronics
              Command, (4) Naval Air Systems Command’s Naval Air Warfare Center,
              (5) Defense Intelligence Agency’s Virginia Contracting Activity and (6)
              Defense Logistics Agency’s Defense Supply Center Philadelphia. We
              discussed with procurement officials at each of these buying organizations
              the reliability of DCADS’s test program data and the program benefits
              realized.

              We conducted our work from March through August 2003 in accordance
              with generally accepted government auditing standards.




              Page 9                         GAO-03-1068 Simplified Acquisition Test Procedures
Appendix II: Comments from Department of
Justice’s Federal Bureau of Prisons




(120216)
             Page 10     GAO-03-1068 Simplified Acquisition Test Procedures
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