Recommendation: To provide better transparency and a coordinated approach in awarding MACs and enterprisewide contracts, the Director of the Office of Management and Budget should direct the Administrator of the Office of Federal Procurement Policy to survey departments and agencies to update the 2006 Office of Federal Procurement Policy Interagency Contracting Data Collection Initiative to identify the universe of MACs and enterprisewide contracts in use throughout federal departments and agencies and assess their utility for maximizing procurement resources across agencies.

Agency Affected: Executive Office of the President: Office of Management and Budget

Status: Open

Comments: The Office of Federal Procurement Policy (OFPP) is working with the agencies to update the current data on interagency contracts. In addition to updating the 2006 data collection, OFPP anticipates requesting agencies provide information during their next acquisition status meeting about their existing contracts that are available for use by other agencies. OFPP will conduct its second round of acquisition status reviews with agencies over the coming months. As with the first status sessions, the purpose of the reviews is to provide an understanding of where the agency is having success, where it is having difficulty in making systemic improvements, and where OFPP can assist the senior acquisition leaders. During the upcoming reviews, agencies will be asked to provide current information about their enterprisewide and interagency agency contracts.

Recommendation: To provide better transparency and a coordinated approach in awarding MACs and enterprisewide contracts, the Director of the Office of Management and Budget should direct the Administrator of the Office of Federal Procurement Policy to ensure that departments and agencies use the survey data to accurately record these contracts in FPDS-NG.

Agency Affected: Executive Office of the President: Office of Management and Budget

Status: Closed - Implemented

Comments: OFPP continues to work with the agencies to ensure that the data reported in the federal procurement data system (FPDS) are accurate and complete. Agencies were asked to randomly sample fiscal year 2010 contract action records and to compare the records to the data captured in FPDS. For the sample taken for the funding agency FPDS field, a key field indicating use of another agency's contract, the government-wide accuracy rate for the sample was 96.5 percent. OFPP will continue to work with agencies to ensure that they have policies, procedures, and internal controls in place to monitor and improve procurement data quality generally. In support of the broader effort to improve the quality of data reported in FPDS, on May 31, 2001, OFPP issued a memorandum describing the steps agencies are expected to take to ensure that FPDS data and other acquisition-related information are reported correctly. An interagency procurement data quality working group has been established and will be considering various efforts agencies are employing to improve data quality and looking to leverage successful efforts across the acquisition community.

Recommendation: To provide better transparency and a coordinated approach in awarding MACs and enterprisewide contracts, the Director of the Office of Management and Budget should direct the Administrator of the Office of Federal Procurement Policy to establish a policy and procedural framework in conjunction with agencies for establishing, approving, and reporting on new MACs and enterprisewide contracts on an ongoing basis; the framework should stress the need for a consistent approach to leveraging the government's buying power across departments and agencies while continuing to use their statutory authorities for buying goods and services.

Agency Affected: Executive Office of the President: Office of Management and Budget

Status: Open

Comments: OFPP is close to finalizing business case guidance that establishes a framework for reviewing and approving business cases. The new business case process will help agencies determine if expected return from investment in a contract or blanket purchase agreement (BPA) is worth the effort. The new business case process will address requirements outlined in section 865 of the FY 2009 National Defense Authorization Act, recommendations made the GAO's 2010 report on interagency and agency-wide contracting, and findings and recommendations made by the Acquisition Advisory Panel. While the guidance is not yet final, below are the main features: 1. Business case requirements will cover all major interagency contracts and certain agency-specific contracts. Our goal is to have guidance that will cover GWACs, multi-agency contracts, and BPAs. Covering the full range of contracts will provide a more comprehensive picture to indicate if there is unhealthy overlap between them. 2. The guidance will retain many of the basic elements that have been used successfully to evaluate proposed GWACs. 3. The new guidance will require an agency to expressly consider the potential for duplication and to describe how its proposed vehicle is unique. 4. Agencies will identify the costs for awarding and managing the vehicle and the amount of fees. 5. An appropriate mechanism will be developed to allow rapid, informal feedback from stakeholders to assist agencies in identifying available vehicles and potential duplication. 6. To improve reporting and visibility of these vehicles, agencies will be required to post on MAX links to web pages containing information about their vehicles. GAO has recommended consideration of a centralized database of interagency and agency-wide contracts. We are committed to ensuring adequate information is available on interagency and agency-wide contracts, so agency acquisition planners can evaluate available options before awarding contracts. Our research has led us to conclude that the limited number of multi-agency contracts that we know of is more a reflection of current reality than data inadequacies-- that is, there are, in fact, a limited number of multi-agency contracts beyond the GSA Schedules and GWACs. Accordingly, we believe that information on the great majority of the available options is already available to agency acquisition personnel. The major sources of interagency contract activity--the Schedules and GWACs--are well known to the acquisition community and provide readily accessible information on their contracts to interested sources. In addition, we have identified at least one commercial source that a number of agencies use to obtain information about the existing non-schedule interagency contracts and large agency-wide contracts. As a result, while we will continue to consider ways to help ensure the ready availability of information, it appears the effort to create a new and potentially costly government-run database of interagency contracts may be unnecessary. Until a determination has been made regarding the creation of a centralized database, agencies will be notified about a new page on the MAX system to find links to web pages with information about government-wide acquisition contracts (GWACs) and other known interagency contract vehicles. In addition, agencies will also be asked to post information about new multi-agency contracts and multi-agency blanket purchase agreements on the MAX page.

Recommendation: To provide better transparency and a coordinated approach in awarding MACs and enterprisewide contracts, the Director of the Office of Management and Budget should direct the Administrator of the Office of Federal Procurement Policy to assess the feasibility of establishing and maintaining a centralized database, which could provide sufficient information on GWACs, MACs, and enterprisewide contracts, for contracting officers to conduct market research and make informed decisions on the availability of existing contracts to meet the agencies' requirements.

Agency Affected: Executive Office of the President: Office of Management and Budget

Status: Closed - Implemented

Comments: OFPP is committed to ensuring adequate information is available on interagency and agency-wide contracts, so agency acquisition planners can evaluate available options before awarding contracts. Our research has led us to conclude that the limited number of multi-agency contracts that we know of is more a reflection of current reality than data inadequacies, that is, there are, in fact, a limited number of multi-agency contracts beyond the GSA Schedules and GWACs. Accordingly, we believe that information on the great majority of the available options is already available to agency acquisition personnel. The major sources of interagency contract activity - the Schedules and GWACs - are well known to the acquisition community and provide readily accessible information on their contracts to interested sources. In addition, we have identified at least one commercial source that a number of agencies use to obtain information about the existing non-schedule interagency contracts and large agency-wide contracts. As a result, while we will continue to consider ways to help ensure the ready availability of information, it appears the effort to create a new and potentially costly government-run database of interagency contracts may be unnecessary. Until a determination has been made regarding the creation of a centralized database, agencies will be notified about a new page on the MAX system to find links to web pages with information about government-wide acquisition contracts (GWACs) and other known interagency contract vehicles. In addition, agencies will also be asked to post information about new multi-agency contracts and multi-agency blanket purchase agreements on the MAX page.

Recommendation: To provide better transparency and a coordinated approach in awarding MACs and enterprisewide contracts, the Director of the Office of Management and Budget should direct the Administrator of the Office of Federal Procurement Policy to, as part of developing the pending FAR rule to implement the 2009 National Defense Authorization Act, ensure that departments and agencies complete a comprehensive business case analysis as described by the SARA panel, and include a requirement to address potential duplication with existing contracts, before new MACs and enterprisewide contracts are established.

Agency Affected: Executive Office of the President: Office of Management and Budget

Status: Open

Comments: In December 2010 the FAR was updated to require agencies take specific actions before using an interagency contract. The FAR update, which implements section 865 of the Duncan Hunter National Defense Authorization Act (NDAA) for Fiscal Year 2009, is designed to ensure the benefits of interagency contacting are consistently achieved. In conjunction with the FAR update, OFPP is developing guidance that includes a new process for developing, reviewing, and approving business cases that will greatly improve the communication and visibility for proposed interagency and agency-specific contract vehicles. This visibility will help OFPP determine whether agencies are implementing and following the guidance. The new guidance will require an agency to expressly consider the potential for duplication and to describe how its proposed vehicle is unique.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should, in coordination with the GSA Inspector General, target the use of pre-award audits to cover more contracts that meet the audit threshold.

Agency Affected: General Services Administration

Status: Closed - Implemented

Comments: The MAS Program Office in conjunction with the Office of the Inspector General (OIG) targeted additional MAS contracts for pre-award audits. GSA guidance instructs contract negotiators to request audit assistance for new contract offers and extensions as appropriate when a contract's estimated sales exceed $25 million for the 5-year contract period. However, not all contracts that meet this threshold receive an audit. For example, 69 preaward audits were completed in fiscal year 2008. The GSA Inspector General's audit planning effort for the two year period of 2009 through 2011, more than 250 contracts that exceeded the $25 million threshold were not selected for audit due to resource contracts. Pre-award audits can result in lower prices for the users of MAS contracts by identifying opportunities for GSA to negotiate more favorable price discounts when awarding contracts. The GSA Inspector General has identified almost $4 billion in potential cost avoidance through pre-award audits from fiscal year 2004 through 2008. In November 2010, in response to GAO's recommendation, GSA developed a plan to conduct 118 pre-award audits in fiscal year 2011, a 70 percent increase compared to the number of preaward audits conducted in fiscal year 2008.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should fully implement the process that has been initiated to ensure that vendors that meet the pre-negotiation clearance panel threshold receive a panel review.

Agency Affected: General Services Administration

Status: Open

Comments: GSA is taking steps to improve the process for conducting pre-negotiation panel reviews. The acting commissioner for the Federal Acquisition Service, GSA, testified before the Senate Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight on June 30th, 2010, and stated that an appropriate threshold for new offers and contract modifications is established for each Schedule based on the relative volume of business which is realized in that industry sector. GSA is updating the policies and procedures for conducting these reviews to ensure that all offers and contract modifications meeting the threshold actually receive a panel review, and that all reviews are conducted in a consistent manner, prior to entering into discussions with the offeror. GSA is also taking steps to ensure that the acquisition systems capture that the review occurred and the results of that review. We will follow up next cycle to determine the outcome of these efforts.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should, when considering the MAS Advisory Panel recommendations to clarify the price objective and eliminate the price reduction clause, ensure that any alternative means to negotiate and determine best prices are validated and in place before eliminating these pricing provisions.

Agency Affected: General Services Administration

Status: Closed - Not Implemented

Comments: The MAS Advisory Panel, a Federal Advisory Committee tasked with providing independent advice to GSA to help ensure to negotiate the best prices possible for GSA's customers. GSA reviewed the Panel recommendations on the MAS program and according to GSA, many changes are already in place or in process, either as a result of or in sync with the Panel recommendations. However, no regulatory actions has been taken to eliminate the price reduction clause.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should collect transactional data on MAS orders and prices paid, possibly through the expanded use of existing electronic tools or through a pilot data collection initiative for selected MAS schedules and make the information available to MAS contract negotiators and customer agencies.

Agency Affected: General Services Administration

Status: Open

Comments: The acting commissioner for the Federal Acquisition Service, GSA, testified before the Senate Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight on June 30th, 2010, and stated that GSA will perform an analysis of how to collect transactional data on MAS orders and prices paid. Concurrently, GSA will initiate conversations with its stakeholders to ensure that their concerns are addressed. A high # level analysis has been completed and a decision paper is planned to be completed by 9/15/2011. We will follow up next cycle to determine the steps GSA has taken to collect transaction level data.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should establish more consistent performance measures across the MAS program, including measures for pricing.

Agency Affected: General Services Administration

Status: Open

Comments: The acting commissioner for the Federal Acquisition Service, GSA, testified before the Senate Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight on June 30, 2010, and stated that GSA is improving the development of performance measures across the MAS Program particularly as they relate to quality, which will address pricing. This will ensure that FAS' acquisition centers and business lines use a more consistent approach to performance measurement across the MAS Program. GSA is establishing a MAS Program Wide scorecard and will incorporate measures into program wide scorecard in October 2011. We will follow up next cycle to identify the improvements GSA has made as a result of ongoing efforts.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should take steps to increase the MAS customer survey response rate by using a methodologically sound means to identify bona fide program users and employing survey techniques that produce meaningful and actionable information that can lead to program improvements.

Agency Affected: General Services Administration

Status: Open

Comments: The acting commissioner for the Federal Acquisition Service, GSA, testified before the Senate Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight on June 30, 2010, and stated that GSA will examine its overall customer satisfaction survey methodology and investigate ways to increase the response rate. Customer satisfaction is a critically important performance measure to GSA and provides meaningful and actionable information that can lead to program improvements. GSA plan to document its overall survey methodology by 9/30/2011. We will follow up next cycle to identify the improvements GSA has made to improve its survey of customer agencies.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should clarify and strengthen the MAS program office's charter and authority so that it has clear roles and responsibilities to consistently implement guidance, policies, and best practices across GSA's acquisition centers including policies and practices related to the above recommendations.

Agency Affected: General Services Administration

Status: Open

Comments: The acting commissioner for the Federal Acquisition Service, GSA, testified before the Senate Homeland Security and Governmental Affairs, Subcommittee on Contracting Oversight on June 30, 2010, and stated that GSA will examine the MAS Program Office charter and authority in an effort to establish more clear roles and responsibilities and to consistently implement guidance, policies and best practices across GSA's acquisition centers and business portfolios. A pre-decision paper has been completed and action will be taken soon. We will follow up next cycle to identify the improvements GSA has made to the program office's charter and authority and steps it has taken to consistently implement policies and practices across GSA's acquisition centers.

Recommendation: To strengthen GSA MAS program pricing and management, the Administrator of the General Services Administration should report GSA's plans to address these recommendations to the Administrator of the Office of Federal Procurement Policy.

Agency Affected: General Services Administration

Status: Closed - Implemented

Comments: On November 22, 2010, GSA provided the Office of Federal Procurement Policy with an update of its plan and status to address the recommendations from GAO. This update included a summary of each recommendation and the current actions taken by GSA.