1. Agree to format discussed at IARC meeting unless DOI chooses to report as NASA does by simply citing a percentage of service contracts or service contract dollars over a given threshold.
Response: We are not able to simply report on all PBSCs as a proportion of all our service contracts without modification of IPDS to add PBSC data elements. IPDS data would not track the transition or conversion activities and savings in the renegotiation of contracts.
2. Until such time as the departmental acquisition system collects the specific information desired/required to be reported to OMB, retain a threshold at a higher level than $100,000. Suggest the same level as IRMRC approval threshold for IT investment or not less than actions estimated at $500,000/yr in value over their contract life.
Response: Agreed. The $500,000 threshold was adopted and made part of the policy released for comment on August 1, 1997.
1. Lacks specific instructions for completing the "Conversion Savings" section of the report.
Response: Agreed. The policy was modified to add instructions explaining reporting of conversion savings. See footnote 4 on the reporting formats.
2. We are concerned about the due date for report submission of October 15. It is unrealistic for us to submit the subject report so close to the end of the fiscal year. We recommend the establishment of a due date at least 30 days after the end of the fiscal year.
Response: Agreed. The October 15 due date was changed to October 31, 1997.
3. We suggest that PAM consider the possibility of automating the report so that applicable information could be obtained from existing electronic data systems (i.e IPDS, IDEAS). In the current environment of downsizing and emphasize on information technology it seems appropriate that an automated system be implemented.
Response: Automation of the reporting was considered and discussed at the IARC meeting On July 24, 1997. The annual number of actions subject to reporting if the threshold were $100,000 or more would only be about 353 per year (based on figures from the December 1997 Passback Survey). At the $500,000 threshold, we estimate the reporting may cover as few as 35 to 47 PBSC actions per year. This low volume coupled with the fact that OMB's reporting requirement is new, untested, and may change in the near future, makes it impractical to invest in automation at this time.
4. Item "d" under "action required" appears to be more of a statement of fact rather than a description of specific action required. Should this be included in a different section of the DIAPR?
Response: Agreed. The statement was moved to the background section.
5. As procurement offices and staffs continue to be downsized any additional reporting requirements will place a burden on these offices and should be evaluated in that light. Has PAM/OMB considered the cost of vs. benefit received from this reporting requirement?
Response: OMB is placing a high priority on use of PBSC techniques. OMB has directed development of agency tracking and reporting systems because of the benefits it sees in their use. This view led to the OMB and Departmental management decisions to establish reporting systems to tract usage. We have considered the cost and burden of reporting by creating a system that meets OMB's requirements and is as simple as possible.
One question raised was regarding conversion of fixed-price service contracts to PBSC's. Is this what was meant by the language in item No. 2 on the reporting form which stated "It also includes changing detailed prescriptive work statements that describe what is to be done not how the work is to be done"?
Response: Yes. The definition of conversion was revised to make this point.
One minor suggestion is to delete the word "done" and replace it with the word "performed" or "accomplished".
Response: Agreed. The suggested change was made.
A general comment is that reports should be at the minimum required level, and that data should be captured only one time.
Response: We have established the reporting activity at a minimal level as noted in response to the preceding comments from MMS. The FY1997 reporting will be a one time data collection. Future reporting tracts planned as well as actual awards as suggested by OMB.
The draft Interior Policy Release on "Performance-Based Service Contracting (PBS) Reporting" requires reporting only on projects over $500,000 for FY 97 and beyond. The Bureau should, therefore, not consider or suggest data collection on PBSC's between $25,000 and $500,000. Threshold of reporting should be only what OMB requires, no more.
Response: The comment applies only to BLM procedures.
We suggest that USDI finalize its final reporting requirements before the Bureau spends additional time further drafting its instruction memorandum.
Response: The comment applies only to BLM procedures.
It appears BLM is not involved in any conversion projects; therefore, we have no comments on the data elements for conversions.
Response: No action suggested or required.
The reporting frequency should meet OMB's requirements - no more frequently. Since "semi-annual" is a consideration by USDI beginning in FY 98, is "semi-annual" OMB's requirement?
Response: OMB left it to agencies to establish the frequency of reporting. We think the reporting burden would be minimized if Bureau contracting offices set up the contract register we drafted for completion as each covered action is awarded. Reviewing a year's actions for completion of the report after the fact would be far more time consuming. The semi-annual reporting is meant to encourage the on-going data collection on contract registers. Regular maintenance of registers will make the summary reporting as easy and quick as possible. The final policy has been modified to make this additional point. See DIAPR subparagrapgh 5 e.
We suggest that the Department, and preferably OMB, begin revising the Interior Procurement Data System (IPDS)/SF279 reporting requirements immediately, so the semiannual reports due April 15 and October 15 can be retrieved by the Department. Much of the data being considered for collection, i.e., contract action, contract type, expiration date, annual cost, award date, etc., are already entered into the IPDS/SF279 report. The few additional items could be added at the end of the IPDS/SF279 report. An additional manual reporting requirement would therefore not be required.
Response: This comment was also made by MMS. See the response in that section.
Footnote 1: The newly revised form (8/1/97 release) has no reference to footnote 1 in data elements. We also note that this form no longer has any reference to FY98 data being collected in this format. We suggest the data to be collected for FY99 should be available in the IPDS, as discussed above:. This form should be used for manual collection of FY97 data only.
Response: The cross reference to Footnote 1 was missing because of a typing error which has been corrected. The reference to FY 1998 reporting and the Service Contract Register (which was on an earlier draft) was dropped from the proposed DIAPR to limit the first round of reporting to FY'97. This approach was chosen to allow changes to the format, if needed, for the next round of reports in FY '98. However, the FY1998 data collection and reporting requirements, and the Service Contract Action Register, are parts of the final policy to communicate the requirement for continued data collection and reporting at this time. We also explained how using the contract register is intended to minimize the reporting burden. See subparagraphs 5 b. c and e, and Attachment 2 which provides the format for the Service Contract register and FY 1998 reporting.
Footnote 2: Why are the column headings, for "Conversion-Y/N" and "Conversion Savings", as shown under "Service Contract Actions (3)", not included under "Current Contract Data (2)" where conversions are to be reported?
Response: The Service Contract Action section is to include data on all new actions of $500,000 or more. The contract action may follow-on from a prior ("Current Contract") or not. Since this was not clear to BLM, we changed the term "Current Contract Data" to "Prior Contract Data." Language was also added to footnote 2 for Prior Contract Data to make the distinction between the two sections clearer.
Footnote 3: This footnote includes the, explanation that these data elements are to be reported for planned awards. However, the column headings for, "Conversion-Y/N" and a column heading for "Conversion Savings" are included (see comments for Footnote 2). If this section is for planned awards, there should be no conversion reporting involved, therefore, these directions are confusing.
Response: The footnote was meant to apply to the Estimated Award Date column
and the Estimated Annual Cost column. The placement of the footnote 3 has been corrected and
the language was revised.
The text of the policy was also revised to make the point that the mid-year, April, report must
include planned FY 1998 actions as well as awards. See
subparagraph 5c.
(1) It seems premature to implement a performance-based service contracting reporting system prior to providing Departmentwide training for contracting officers and program personnel in the development of performance-based statements of work, contract performance measurement, conversions, and the evaluation of past performance. The quality and accuracy of performance based data collected through the proposed report will be questionable until all major role players receive proper training in performance-based contracting. Proper training in this area is a prerequisite to the production of accurate reports and the establishment of a reliable reporting system.
Response: MMS has just recently awarded a contract for PBSC training. A seperate formal announcement will be issued shortly. While the training will be available on demand, it follows OMB, OFPP and Departmental establishment of a number of policies including the reporting requirement. It may require a year or more for Bureaus to fund and send Contracting Officers and COTRs to training. It would be unrealistic to delay compliance with the reporting and tracking pending completion this training cycle.
(2) Item 5.a. of the proposed policy release states that reporting "is to be on all actions with an individual value of $500,000 or more." Item 5.c. further states that "contract performance reports, see DIAPR 1997-5 and FAR 42.1502, will be used to track the general benefits of using these techniques with respect to price, performance (including timeliness) and customer satisfaction. Final performance reports will be used for benefit comparisons on conversions." As you are aware, DIAPR 1997-5 implemented the Office of Federal Procurement Policy's suspension of the contract performance reporting requirements' schedule at FAR 42.1502(a), and required that contract performance reports be collected only for contracts in excess of $1 million. Why is the Department of the Interior asking its bureaus to issue and use final performance reports for actions with individual values of $500,000 or more, which is considerably lower than the $1 million threshold established in February 1997 under DIAPR 1997-5?
Response: We have not asked for additional performance reports below $1 million. The DIAPR refers to the implementation of OFPP's suspension of contract performance reporting but did not say that Interior was lowering the $1 million threshold to $500,000. There was no intention to do that. Additional text was added to paragraph 5.d. to make it clear that the contract $1 milion performance reporting threshold is not being changed by this DIAPR.
(3) How will the referenced Performance-Based Service Contract (PBSC) Report be made available to DOI bureaus and offices? Will a site be made available on the Office of Acquisition and Property Management's home page? We should try to avoid paper-based reporting systems as much as possible. We hope that PAM will identify the most efficient, and least burdensome means for collecting performance-based reporting data.
Response: Once the data is summarized we will report the results either through an
IARC memo or IARC meeting.
We will need to see the results before deciding to put it on the home page.
The report format will be distributed electronically through CC:Mail and through internal
mail. We can receive it through E-mail or compile results from paper copies. We added
another provision, subparagraph 5 f. , asking BPCs to compile the results for their bureaus
and send summary reports to us via E-mail.