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the Simplified Acquisition Test Program' which was released on 
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Report to Congressional Committees:

United States General Accounting Office:

GAO:

September 2003:

CONTRACT MANAGEMENT:

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

Simplified Acquisition Test Procedures:

GAO-03-1068:

GAO Highlights:

Highlights of GAO-03-1068, a report to the Senate and House Committees 
on Armed Services

Why GAO Did This Study:

In recent years, the federal government has introduced new ways to 
streamline the acquisition process. One of those vehicles is the 
simplified acquisition procedures test program, which removes some of 
the procedural requirements for buying commercial goods and services. 
Using the test program, federal procurement officials can make 
purchases faster than they have in the past for procurements not 
exceeding $5 million.

Congress mandated that GAO determine the extent to which federal 
executive agencies—at a minimum, the Department of Defense (DOD)—have 
taken advantage of the test program and any benefits realized. One way 
to measure use is to examine test program data from the Federal 
Procurement Data System (FPDS). It is the central repository of 
contracting information. In addition to examining FPDS data, GAO 
looked at data from DOD’s data system.

What GAO Found:

Because the Federal Procurement Data System contains unreliable data 
about the simplified acquisition test program, GAO was unable to 
determine the extent to which federal executive agencies—including 
DOD— have used the test program and have realized any benefits. 
Specifically, the database indicated that the Departments of Treasury, 
Defense, and Justice were the three largest dollar-value users of the 
test program in fiscal year 2001 (the latest year with complete data 
available). But GAO found that FPDS either overstated or understated 
use of the test program by millions of dollars. The table below shows 
examples of discrepancies at different buying organizations within 
these three departments.

Examples of Discrepancies with FPDS’s Data

[See PDF for image]

[End of table]

GAO also found data reliability problems with contract data in DOD’s 
own data system—the Defense Contract Action Data System (DCADS)—which 
feeds into FPDS on an ongoing basis. For example, for fiscal year 
2002, 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 dollar value, procurement officials at these two DOD 
buying organizations said that none of the entries were awarded 
through the test program. There were also reliability problems at 
other buying commands. 

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. 
Anecdotal evidence indicates that the test program is getting 
favorable reviews. For example, nearly all procurement officials with 
whom GAO spoke at the buying organizations GAO visited indicated that 
the program’s primary benefit is the ability to process a contract 
more efficiently.

What GAO Recommends:

Before Congress decides whether to make the test program a permanent 
contracting vehicle, GAO recommends that DOD and other selected 
federal executive agencies ensure that reliable data are available to 
make program assessments. DOD agreed with GAO’s recommendation, while 
the other selected federal agencies had no comments on the 
recommendation.

www.gao.gov/cgi-bin/getrpt?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.

[End of section]

Contents:

Letter:

Results in Brief:

Background:

No Reliable Data Available to Assess Test Program:

Conclusion:

Recommendations for Executive Action:

Agency Comments:

Appendix I: Scope and Methodology:

Appendix II: Comments from Department of Justice's Federal Bureau of 
Prisons:

Table:

Table 1: Examples of Discrepancies with FPDS's Data:

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:

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.[Footnote 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 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.

Results in Brief:

Because the FPDS and DCADS databases contain unreliable test program 
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.

Background:

To streamline the federal procurement process, Congress in 1994 
authorized the use of simplified acquisition procedures for purchases 
not exceeding $100,000.[Footnote 2] Simplified procedures allow agency 
officials to expedite the evaluation and selection processes and keep 
documentation to a minimum.

In 1996, Congress expanded the use of simplified acquisition 
procedures[Footnote 3] by authorizing a test program that allows 
government buyers to procure commercial items not exceeding $5 
million[Footnote 4] in order to maximize efficiency and economy and 
minimize burden and administrative costs for both the government and 
industry.[Footnote 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.[Footnote 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 
purchases.[Footnote 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.

No Reliable Data Available to Assess Test Program:

We found significant data-reporting errors related to the test program 
in both FPDS's and DCADS's databases. Because of unreliable data, we 
were unable to determine the extent to which federal executive agencies 
have used the simplified acquisition test program and what benefits 
they may 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 
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 buying organization: Department of the Treasury's U.S. 
Mint; Value of test program contracts, according to FPDS (fiscal year 
2001): $242 million; What procurement officials said about 
FPDS's data: U.S. Mint said it did not use the test program at all.

Department's buying organization: DOD's Defense Logistics Agency; Value 
of test program contracts, according to FPDS (fiscal year 2001): $4 
million; What procurement officials said about FPDS's data: 
Defense Logistics Agency said it obligated $146 million in test program 
contracts.

Department's buying organization: Department of Justice's Federal 
Prison Industries; Value of test program contracts, according to FPDS 
(fiscal year 2001): $118 million; What procurement officials 
said about FPDS's data: After reviewing portions of FPDS's data, about 
$31 million in contract actions, Federal Prison Industries said none of 
those items were purchased under the test program.

Sources: FPDS (data); GAO (analysis).

[End of table]

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 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.

Conclusion:

The simplified acquisition test program, which streamlines the process 
for 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 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.

Recommendations for Executive Action:

Before Congress provides permanent authority for using simplified 
procedures to acquire commercial items costing up to $5 million, we 
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.

Agency Comments:

We asked OFPP and the Departments of Treasury, Justice, and Defense for 
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.

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:

Signed by David E. Cooper: 

[End of section]

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.

[End of section]

Appendix II: Comments from Department of Justice's Federal Bureau of 
Prisons:

U.S. Department of Justice 
Federal Bureau of Prisons:

Washington, DC 20534:

September 9, 2003:

Ralph Dawn, Assistant Director Acquisition and Sourcing Management 
General Accounting Office Washington, DC 20548:

Dear Mr. Dawn:

The Bureau of Prisons appreciates the opportunity to formally respond 
to the General Accounting Office's draft report entitled Contract 
Management: No Reliable Data to Measure:

Benefits of the Simplified Acquisition Test Program. We have completed 
our review and concur with the information reflected in the report. The 
report does not contain any recommendations for the BOP.

Thank you for the opportunity to review the draft copy of this report. 
If you have any questions regarding this response, please contact 
Jessie Hobbs, External Liaison, at (202) 305-7401.

Sincerely,

Michael W. Garrett:

Senior Deputy Assistant Director:

Signed by Michael W. Garrett:

FOOTNOTES

[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.

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

[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.

[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). 

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