Interior Dept. | The Contracting Education Academy

March 18, 2014 By AMK

Strategic sourcing’s impact on small biz needs measurement and monitoring, GAO says

“Strategic sourcing” is a method used by the federal government to improve procurement efficiency by moving away from numerous individual procurements toward a broader aggregate approach. Since 2005, the Office of Management and Budget (OMB) has encouraged federal agencies to use strategic sourcing.

Now, the Government Accountability Office (GAO) has issued a report on how strategic sourcing affects small businesses, including small disadvantaged businesses. The report discusses: (1) how OMB, GSA, and selected agencies have considered small businesses in their strategic sourcing efforts, and (2) the extent to which data and performance measures are available on the inclusion of small businesses in strategic sourcing initiatives.

In its review, GAO found that OMB and the General Services Administration (GSA) have developed guidance on strategic sourcing that stresses the importance of including small businesses. GAO’s review of documentation for three ongoing government-wide strategic sourcing initiatives showed that GSA considered the inclusion of small businesses in the strategic sourcing process. For example, when developing strategic sourcing initiatives for office supplies and print management, GSA identified the current market share of small businesses with these products and also set aside specific contracts for various categories of small businesses, such as service-disabled veteran-owned small businesses. In addition, GAO’s review of agency-wide strategic sourcing initiatives at each of five agencies — Departments of Defense (DOD), specifically Army and the Defense Logistics Agency; Homeland Security (DHS); Housing and Urban Development (HUD); and the Interior and the National Aeronautics and Space Administration (NASA) — showed that the agencies generally considered the inclusion of small businesses.

However, data and performance measures that would provide a more precise understanding of the inclusion of small and disadvantaged businesses in strategic sourcing initiatives are limited. GAO’s specific findings include:

Although GSA has collected baseline data on proposed government-wide initiatives, it has not developed a performance measure to determine changes in small business participation going forward.
DHS has collected some data on contracts awarded to small businesses under strategic sourcing initiatives, but it and the other agencies in GAO’s review generally did not have baseline data and performance measures to determine how small businesses were affected by strategic sourcing. OMB guidance requires agencies to establish baselines for small business participation prior to implementing strategic sourcing and set goals for small business participation.
In addition, federal internal control standards state that information is needed to determine whether the agency is achieving its compliance requirements under various laws and regulations. Without baseline data and performance measures, the effect of strategic sourcing initiatives on small businesses will be difficult to determine.
Moreover, OMB has not monitored agencies’ compliance in reporting baseline data and performance measures on the inclusion of small businesses in government-wide and agency-wide strategic sourcing initiatives. OMB required agencies to submit annual reports on the implementation of strategic sourcing from fiscal years 2005 through 2007 and prepare information for acquisition status sessions from fiscal years 2010 through 2012. (No reporting was in place for fiscal years 2008 or 2009.) However, virtually none of this information included baseline data or measures of the effect of strategic sourcing on small businesses.
Federal internal control standards state that effective monitoring should assess the quality of performance over time. Without effective monitoring, it will be difficult for OMB to help ensure that agencies are tracking the impact of strategic sourcing on small businesses.

As a part of its report, GAO made recommendations to GSA, selected agencies, and OMB to improve data collection and performance measures related to the inclusion of small businesses in strategic sourcing. DOD, DHS, GSA, HUD, and OMB agreed with GAO’s recommendation. Interior partially agreed, suggesting that a more effective approach would be to work with OMB and other agencies to develop common approaches. NASA disagreed, stating it already tracks related spending for the agency. GAO believes its recommendations remain valid as discussed in the report.

To download the complete report, click here.

March 12, 2014 By AMK

Government on pace to meet small-business contracting goal — but will the bar get higher?

It appears the federal government has fulfilled its annual contracting promise to small businesses for the first time in seven years — and perhaps just in the nick of time, as lawmakers are looking to raise the bar going forward.

Government data available online currently show that federal agencies spent $83.2 billion at small companies last fiscal year, representing slightly more than 23 percent of the $355 billion in prime federal contracts officials consider viable for small firms. If so, it will mark the first time since 2006 that the government has met its statutory goal of spending at least 23 percent of all federal contracting dollars at small businesses.

More than a quarter of the contracts were awarded by the Defense Department, while the SBA, Federal Communications Commission and Interior Department each spent most of their contracting dollars at small businesses, according to the federal government’s online small business dashboard, which tracks government spending by agency.

SBA officials, who compile the data, declined to comment on the current numbers, saying they could change and the agency will issue an official tally later this year.

Keep reading this article at: http://www.washingtonpost.com/business/on-small-business/government-on-pace-to-meet-small-business-contracting-goal–but-will-the-bar-get-higher/2014/02/26/d3ba6e98-9ef5-11e3-9ba6-800d1192d08b_story.html

Also see: Small business contracting numbers inflated by errors and exclusions, data show – http://www.washingtonpost.com/business/on-small-business/small-business-contracting-numbers-inflated-by-errors-and-exclusions-data-show/2013/07/28/7fa2a4fc-f2f6-11e2-8505-bf6f231e77b4_story.html

November 15, 2013 By AMK

Poor contracting practices cited at Bureau of Land Management

A government employee who stepped into a contractor’s role is among the targets of a report criticizing contracting practices at the Bureau of Land Management.

The Interior Department office of inspector general says in a recently-released report, dated Sept. 30, that a BLM project officer placed a request to modify a contract, “in effect, representing the contractor.”

The project officer and the contracting officer involved had to be counseled on proper contracting practices, the report says. At the time of the report, the BLM was finalizing guidelines to outline the responsibilities and limitations of contracting officers and project officers.

Keep reading this article at: http://www.fiercegovernment.com/story/poor-contracting-practices-blm/2013-10-29?utm_medium=nl&utm_source=internal

A copy of the Interior Department’s IG report is at: http://www.doi.gov/oig/reports/upload/C-EV-BLM-0007-2011Public.pdf

August 16, 2013 By AMK

DOT employees made $58 million in improper purchase card charges, IG says

Nearly a quarter of all Transportation Department employee purchase card transactions in fiscal 2010 and 2011 did not comply with DOT rules for employee spending, a departmental Inspector General report says.

During those years, DOT employees spent $277 million in 450,000 transactions on their purchase cards, the report says. About $58 million of that did not comply with DOT employee spending controls, the report says.

Purchase cards are routinely used to supplies and services, the report says.

DOT auditors based the results on a sample of 413 purchases in which 84, totaling $254,000, did not comply with DOT rules.

Offenses ranged from not receiving approval prior to card use, receiving approval for purchases from officials that were not authorized to approve the purchases and not verifying fund availability prior to purchases.

In the sample, about $93,000 in improper charges were made due to not getting preapproval for a purchase. About $65,000 came from the wrong person approving the purchase. And $47,000 came from purchases made without checking if the funds were available, the report says.

Keep reading this article at: http://www.fiercegovernment.com/story/dot-employees-made-58-million-improper-purchase-card-charges-ig-says/2013-07-31

July 5, 2013 By AMK

Interior Dept. issues final rule guiding implementation of Buy Indian Act, effective July 8th

The Department of the Interior is finalizing regulations guiding implementation of the Buy Indian Act, which provides the Bureau of Indian Affairs (IA) with authority to set aside procurement contracts for American Indian-owned and controlled businesses and Alaska Native-owned and controlled businesses.

The new rule can be found at 78 Fed. Reg. 34266, dated June 7, 2013.

This rule supplements the Federal Acquisition Regulation (FAR) and the Department of the Interior Acquisition Regulation (DIAR), and the final rule is to be effective July 8, 2013.

The rule benefits a broad range of businesses. It requires the Assistant Secretary – Indian Affairs to give preference to “Indian economic enterprises” – defined, in part, as any business entity that is at least 51 percent owned by one or more American Indian or Alaska Native individuals, federally recognized American Indian tribes, or Alaska Native villages and regional or village corporations under the Alaska Native Claims Settlement Act. As a result, engaging in a strategic partnership with a minority non-Indian investor will not disqualify an otherwise eligible Indian business.

The rule supplements the Federal Acquisition Regulation and Department of the Interior Acquisition Regulation, and will be located at 48 C.F.R. Sections 1401.301-80, 1452-280 and 1480. It also responds to and incorporates the nuances of Section 831 of the National Defense Authorization Act for Fiscal Year 1991 (Pub. Law 101-510, 10 U.S.C. 2301 note) that amended 25 U.S.C. 47 to allow American Indian firms to participate in the Department of Defense’s Mentor-Protégé Program and yet maintain eligibility for contracts awarded under the authority of the Buy Indian Act.

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