Service Contracts:

Agencies Should Take Steps to More Effectively Use Independent Government Cost Estimates

GAO-17-398: Published: May 17, 2017. Publicly Released: May 17, 2017.

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Marie Mak
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makm@gao.gov

 

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Independent government cost estimates help the government understand the potential cost of a contract. They're an important planning tool, especially for service contracts.

Some of the agencies that spend the most on service contracts may not be taking advantage of this tool: we found uneven guidance on when to use estimates.

We also found different levels of detail in the estimates themselves, which can affect how useful they are to contracting officers. The details help officers determine, for example, how reasonable a contractor's price is.

We made 5 recommendations to make better use of independent government cost estimates.

Well-Documented Independent Government Cost Estimates (IGCE), per GAO’s Cost Estimating Guide

Bar chart showing that comparatively few estimates in our review were considered well-documented.

Bar chart showing that comparatively few estimates in our review were considered well-documented.

Additional Materials:

Contact:

Marie Mak
(202) 512-4841
makm@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

Officials at the departments in GAO's review—Defense, Homeland Security, Health and Human Services, Education, Labor, and Housing and Urban Development—developed independent government cost estimates (IGCE) for 62 of the contracts GAO reviewed. All of the departments in GAO's review have some guidance on IGCEs available—ranging from regulation to handbooks to checklists—with different emphasis on whether an IGCE is required. GAO found some cases where guidance dictated that an IGCE should have been prepared, but was not. According to officials, one reason for not preparing an IGCE was that the procurement was a task order issued under an existing contract. Federal internal control standards state that agencies should communicate quality information to achieve their objectives, such as including clear guidance for acquisition planning.

In the 62 contracts GAO reviewed with IGCEs, the IGCEs' use in acquisition planning varied—from determining funding needs to determining price reasonableness. The usefulness of an IGCE to a contracting officer depends in part on its supporting documentation, but most IGCEs did not document data sources and methodologies used (see figure) .

Well-Documented Independent Government Cost Estimates (ICGE), per GAO's Cost Estimating Guide

Well-Documented Independent Government Cost Estimates (ICGE), per GAO's Cost Estimating Guide

Lack of documented data sources and methodologies in an IGCE puts contracting officers at a disadvantage and could lead to additional, inefficient steps to validate IGCEs. Only two of the agencies in GAO's review had explicit guidance on what details to document in IGCEs, but officials were not always familiar with the available guidance. Instead, according to the officials GAO spoke with, they often follow program office practices and noted that training did not address how to develop and document an IGCE. GAO's cost estimating guidance and federal internal control standards emphasize the need for documentation, with GAO's guidance stating that well-documented cost estimates should describe the data sources used, underlying assumptions, and the estimating methodologies used to derive costs. Without clear guidance or more training on documentation of data sources and methodologies, departments may not be taking full advantage of this important acquisition tool.

Why GAO Did This Study

IGCEs are the government's best estimate of a contract's potential costs—an important tool for both program and contracting officials to provide information when planning for and awarding contracts. IGCEs are particularly critical for service contracts—accounting for more than $270 billion in government contract spending in fiscal year 2015—to ensure the costs associated with labor are fully understood.

GAO was asked to review federal agencies' use of IGCEs. This report examines the extent to which (1) selected departments developed IGCEs for service contracts and (2) selected departments' IGCEs were useful in supporting the acquisition planning process.

To conduct this work, GAO selected six departments that in fiscal year 2015, the most current data available, were among the top spenders on services or had a high percentage of spending on services. GAO reviewed a random non-generalizable sample of 76 service contracts, and compared IGCEs and related documentation with GAO's cost estimating guide. GAO also conducted interviews with contracting and program officials.

What GAO Recommends

To improve the usefulness of IGCEs, GAO is making five recommendations, including that departments revise or clarify guidance or provide more training to help ensure IGCEs are prepared when required and are well-documented with clearly-stated data sources and methodologies. All six departments agreed with GAO's recommendations.

For more information, contact Marie Mak at (202) 512-4841 or makm@gao.gov.

Recommendations for Executive Action

  1. Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government cost estimates.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense and Housing and Urban Development should take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency Affected: Department of Defense

  2. Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it is writing an acquisition instruction to guide acquisition workforce personnel on when and how to prepare an independent government cost estimate which will address this recommendation. It is also planning training on this issue in the fall of 2017.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense and Housing and Urban Development should take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency Affected: Department of Housing and Urban Development

  3. Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretary of Education should consider making Contracts and Acquisitions Management guidance applicable to all agency procurements, and if so, take steps--such as clarifying guidance, providing additional training, or issuing reminders to officials--to help ensure that guidance on when to prepare an IGCE is followed.

    Agency Affected: Department of Education

  4. Status: Open

    Comments: DHS agreed with the recommendation and stated that it will take steps to determine why guidance on independent government cost estimates is not followed. In July, DHS reported that the Office of the Chief Procurement Officer(OCPO) reached out to the nine DHS contracting activities soliciting feedback on why program officials may not be developing IGCEs in accordance with existing policies. Feedback was received in late May 2017. OCPO is currently evaluating the feedback and identifying consistent themes which will lead to the development of IGCE policy compliance measures.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Defense and Homeland Security should take steps to ensure that IGCE guidance is followed by, for example, providing training or issuing reminders to officials.

    Agency Affected: Department of Homeland Security

  5. Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government estimates.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Defense and Homeland Security should take steps to ensure that IGCE guidance is followed by, for example, providing training or issuing reminders to officials.

    Agency Affected: Department of Defense

  6. Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency Affected: Department of Education

  7. Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it is writing an acquisition instruction to guide acquisition workforce personnel on when and how to prepare an independent government cost estimate which will address this recommendation. It is also planning training on this issue in the fall of 2017.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency Affected: Department of Housing and Urban Development

  8. Status: Open

    Comments: HHS agreed with the recommendation and stated that it will revise guidance on independent government cost estimates.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency Affected: Department of Health and Human Services

  9. Status: Open

    Comments: DOL agreed with the recommendation and stated that it will review guidance and training on independent government estimates.

    Recommendation: To ensure that IGCEs contain key information consistent with good cost estimating practices, the Secretaries of Education, Health and Human Services, Housing and Urban Development, and Labor should revise or clarify guidance to require that IGCEs document data sources, methodology, and assumptions, and take steps to help ensure that guidance is followed by, for example, providing training or issuing reminders to officials to include this information when developing IGCEs.

    Agency Affected: Department of Labor

  10. Status: Open

    Comments: DHS agreed with the recommendation. In July 2017, DHS reported that the Office of the Chief Procurement Officer (OCPO) disseminated a new draft policy on this issue and solicited feedback from the Component's contracting activities. The Components provided feedback on the draft policy and OCPO is currently adjudicating their comments and will incorporate, as appropriate.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Homeland Security

  11. Status: Open

    Comments: Education agreed with the recommendation and stated that it will enhance or clarify guidance on independent government cost estimates.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Education

  12. Status: Open

    Comments: DOD agreed with the recommendation and stated that it is in the process of developing guidance and training on independent government estimates.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Defense

  13. Status: Open

    Comments: HUD agreed with the recommendation. In July 2017, HUD noted that it will remind managers to ensure they review price analysis, pre-negotiation and price negotiation memoranda to ensure that differences between the independent government cost estimate and final contract award value are properly documented in the contract file.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Housing and Urban Development

  14. Status: Open

    Comments: HHS agreed with the recommendation and stated that it will revise guidance on independent government cost estimates.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Health and Human Services

  15. Status: Open

    Comments: DOL agreed with the recommendation and stated that it will review continue to work with contracting officials to ensure proper documentation and issue a policy on this issue no later than the end of fiscal year 2017.

    Recommendation: To ensure that IGCEs are optimized as a tool in the procurement planning process, the Secretaries of Defense, Education, Health and Human Services, Homeland Security, Housing and Urban Development, and Labor should take steps to ensure that, when appropriate, contracting staff document differences between IGCE and final contract award value in the contract file.

    Agency Affected: Department of Labor

 

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