+-------------------+----------------------+---------------------------+
| **Topic**         | **Comment**          | **Action**                |
|                   |                      |                           |
|                   | **Strength (S);      |                           |
|                   | Weakness (W);        |                           |
|                   | Consideration (C)**  |                           |
+-------------------+----------------------+---------------------------+
| **1. Organization |                      |                           |
| Structure and     |                      |                           |
| Staffing**        |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The           |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | still consists of    |                           |
|                   | five offices managed |                           |
|                   | by an Associate      |                           |
|                   | Chief and two        |                           |
|                   | Procurement          |                           |
|                   | Managers. The        |                           |
|                   | Procurement Officer, |                           |
|                   | Deputy, Senior       |                           |
|                   | Staff, Procurement   |                           |
|                   | Support Services     |                           |
|                   | Team, Industry       |                           |
|                   | Assistance Office,   |                           |
|                   | Organizational       |                           |
|                   | Development          |                           |
|                   | Specialist,          |                           |
|                   | Administrative       |                           |
|                   | Support Staff and    |                           |
|                   | Associate Chiefs all |                           |
|                   | reside in the        |                           |
|                   | Center's main        |                           |
|                   | administrative       |                           |
|                   | building. The        |                           |
|                   | Procurement Managers |                           |
|                   | and the remainder of |                           |
|                   | the procurement      |                           |
|                   | personnel are        |                           |
|                   | distributed          |                           |
|                   | throughout the       |                           |
|                   | Center and are       |                           |
|                   | either co-located or |                           |
|                   | in buildings in      |                           |
|                   | close proximity to   |                           |
|                   | the technical        |                           |
|                   | organizations that   |                           |
|                   | they support.        |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** The           |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | is comprised of      |                           |
|                   | personnel with       |                           |
|                   | various skill sets   |                           |
|                   | and positions. Some  |                           |
|                   | of these positions   |                           |
|                   | are being phased out |                           |
|                   | as a result of       |                           |
|                   | certain types of     |                           |
|                   | activities shifting  |                           |
|                   | to the NASA Shared   |                           |
|                   | Services Center. A   |                           |
|                   | small number of      |                           |
|                   | contract             |                           |
|                   | administrators,      |                           |
|                   | grants specialists   |                           |
|                   | and procurement      |                           |
|                   | technicians remain   |                           |
|                   | in the organization. |                           |
|                   | There is no plan to  |                           |
|                   | replace these        |                           |
|                   | positions as the     |                           |
|                   | individuals retire,  |                           |
|                   | leave the Center or  |                           |
|                   | transition into      |                           |
|                   | other positions.     |                           |
+-------------------+----------------------+---------------------------+
| **2. Procurement  |                      |                           |
| Staff             |                      |                           |
| Interviews**      |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | management team is   |                           |
|                   | commended for        |                           |
|                   | establishing an open |                           |
|                   | line of              |                           |
|                   | communications with  |                           |
|                   | procurement          |                           |
|                   | personnel and        |                           |
|                   | proactively          |                           |
|                   | addressing the       |                           |
|                   | weaknesses cited in  |                           |
|                   | the EEO MD 715       |                           |
|                   | survey. Examples     |                           |
|                   | include the series   |                           |
|                   | of small group       |                           |
|                   | discussions between  |                           |
|                   | the Procurement      |                           |
|                   | Officer and          |                           |
|                   | procurement          |                           |
|                   | personnel to         |                           |
|                   | candidly discuss the |                           |
|                   | MD 715 survey        |                           |
|                   | findings and the     |                           |
|                   | recent initiation by |                           |
|                   | some Associate       |                           |
|                   | Chiefs of regular    |                           |
|                   | newsletters          |                           |
|                   | addressing a variety |                           |
|                   | of issues related to |                           |
|                   | Goddard Procurement. |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
| **3. Technical    | **a.** Contracting   |                           |
| Customer          | officers and         |                           |
| Interviews**      | specialists within   |                           |
|                   | the Headquarters     |                           |
|                   | Operations Division  |                           |
|                   | should consider      |                           |
|                   | scheduling periodic  |                           |
|                   | visits to the        |                           |
|                   | Headquarters COTRs   |                           |
|                   | to discuss contract  |                           |
|                   | administration,      |                           |
|                   | responsibilities and |                           |
|                   | other pertinent      |                           |
|                   | issues. . **(C)**    |                           |
+-------------------+----------------------+---------------------------+
| **4. Legal Office |                      |                           |
| Interview**       |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | ensure that the      |                           |
|                   | appropriate level of |                           |
|                   | documentation review |                           |
|                   | is conducted         |                           |
|                   | internally prior to  |                           |
|                   | submission to the    |                           |
|                   | Office of Chief      |                           |
|                   | Counsel for review.  |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | should ensure that   |                           |
|                   | sufficient time is   |                           |
|                   | provided to the      |                           |
|                   | Office of Chief      |                           |
|                   | Counsel for document |                           |
|                   | review to the        |                           |
|                   | maximum extent       |                           |
|                   | possible. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
| **5. Procurement  |                      |                           |
| Career            |                      |                           |
| Development and   |                      |                           |
| Training**        |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement Officer  |                           |
|                   | is commended for the |                           |
|                   | overall quality of   |                           |
|                   | the training         |                           |
|                   | database and backup  |                           |
|                   | documentation.       |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | should ensure that   |                           |
|                   | employees are given  |                           |
|                   | the opportunity to   |                           |
|                   | attend requisite     |                           |
|                   | training for         |                           |
|                   | contracting          |                           |
|                   | certification.       |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **6. Contracting  |                      |                           |
| Officer's         |                      |                           |
| Technical         |                      |                           |
| Representative    |                      |                           |
| (COTR) Training** |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | is commended for the |                           |
|                   | COTR database and    |                           |
|                   | backup               |                           |
|                   | documentation.       |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | should incorporate   |                           |
|                   | fields into the      |                           |
|                   | database for         |                           |
|                   | contract number      |                           |
|                   | (i.e. contract or    |                           |
|                   | grant), contract     |                           |
|                   | completion date and  |                           |
|                   | indicate that the    |                           |
|                   | COTR/ Technical      |                           |
|                   | Officer is actively  |                           |
|                   | delegated            |                           |
|                   | responsibilities and |                           |
|                   | ensure that all      |                           |
|                   | fields in the Active |                           |
|                   | COTR database are    |                           |
|                   | populated and amend  |                           |
|                   | the list to include  |                           |
|                   | the last year and/   |                           |
|                   | or the two most      |                           |
|                   | recent training      |                           |
|                   | sessions. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** After meeting |                           |
|                   | with several of the  |                           |
|                   | COTRs it was         |                           |
|                   | recommended that the |                           |
|                   | COTR course include  |                           |
|                   | information          |                           |
|                   | specifically for     |                           |
|                   | Task Managers, SBIR  |                           |
|                   | COTRs and Technical  |                           |
|                   | Officers within the  |                           |
|                   | training or held as  |                           |
|                   | a separate training  |                           |
|                   | to ensure they       |                           |
|                   | understand their     |                           |
|                   | roles specifically   |                           |
|                   | to their positions.  |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **7. Internal     |                      |                           |
| Policies and      |                      |                           |
| Procedures**      |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | is commended for the |                           |
|                   | overall quality of   |                           |
|                   | the Center\'s        |                           |
|                   | procurement policies |                           |
|                   | and procedures.      |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | incorporate a        |                           |
|                   | web-link to the      |                           |
|                   | Programs and Project |                           |
|                   | Management guidance  |                           |
|                   | on developing and    |                           |
|                   | writing Technical    |                           |
|                   | Evaluations into its |                           |
|                   | procurement policy   |                           |
|                   | website **(C)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | c\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | amend their warrant  |                           |
|                   | policy for Level II  |                           |
|                   | certified contract   |                           |
|                   | specialists to       |                           |
|                   | ensure compliance    |                           |
|                   | and consistency with |                           |
|                   | the Agency warrant   |                           |
|                   | policy. (W)          |                           |
+-------------------+----------------------+---------------------------+
| **8.              |                      |                           |
| Self-Assessment   |                      |                           |
| Program**         |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a.The                |                           |
|                   | self-assessment      |                           |
|                   | process at Goddard   |                           |
|                   | is highly effective  |                           |
|                   | at addressing issues |                           |
|                   | at the Center and    |                           |
|                   | developing           |                           |
|                   | corrective actions   |                           |
|                   | to address           |                           |
|                   | shortfalls. The      |                           |
|                   | process includes an  |                           |
|                   | exceptional feedback |                           |
|                   | mechanism to ensure  |                           |
|                   | individual           |                           |
|                   | accountability and   |                           |
|                   | management           |                           |
|                   | oversight. **(S)**   |                           |
+-------------------+----------------------+---------------------------+
| **9. Master Buy   |                      |                           |
| Plans Records**   |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | must ensure that MBP |                           |
|                   | Record submissions   |                           |
|                   | are sufficiently     |                           |
|                   | detailed, and that   |                           |
|                   | particular attention |                           |
|                   | is given to the      |                           |
|                   | Description, and     |                           |
|                   | Status Schedule Data |                           |
|                   | Fields. **(C)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** NASA HQ       |                           |
|                   | Office of            |                           |
|                   | Procurement should   |                           |
|                   | consider making the  |                           |
|                   | Status/Schedule      |                           |
|                   | Field mandatory.     |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **10. Deviations  |                      |                           |
| and Waivers**     |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** It is         |                           |
|                   | recommended that the |                           |
|                   | Procurement Policy   |                           |
|                   | Senior Staff         |                           |
|                   | maintain a file of   |                           |
|                   | approved deviations  |                           |
|                   | and waivers. **(C)** |                           |
+-------------------+----------------------+---------------------------+
| **11.             |                      |                           |
| J                 |                      |                           |
| OFOCs/Competition |                      |                           |
| Advocacy**        |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | is commended for the |                           |
|                   | overall quality of   |                           |
|                   | the JOFOC\'s         |                           |
|                   | reviewed. **(S)**    |                           |
+-------------------+----------------------+---------------------------+
| **12.             |                      |                           |
| Acquisitions in   |                      |                           |
| Process**         |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** For           |                           |
|                   | acquisitions of all  |                           |
|                   | sizes, the reviews   |                           |
|                   | indicated that the   |                           |
|                   | overall source       |                           |
|                   | selection process    |                           |
|                   | was effective and    |                           |
|                   | resulted in timely   |                           |
|                   | awards of            |                           |
|                   | procurements. For    |                           |
|                   | non-competitive      |                           |
|                   | actions, the sole    |                           |
|                   | source documentation |                           |
|                   | was generally        |                           |
|                   | thorough and         |                           |
|                   | followed the         |                           |
|                   | required FAR format. |                           |
|                   | For large            |                           |
|                   | competitive          |                           |
|                   | acquisitions, source |                           |
|                   | evaluation teams     |                           |
|                   | were appointed prior |                           |
|                   | to receipt of        |                           |
|                   | proposals.           |                           |
|                   | Evaluation           |                           |
|                   | documentation was    |                           |
|                   | also found to be     |                           |
|                   | very thorough and    |                           |
|                   | comprehensive. When  |                           |
|                   | not performed by the |                           |
|                   | contract specialist, |                           |
|                   | pricing support for  |                           |
|                   | competitive actions  |                           |
|                   | was provided by      |                           |
|                   | dedicated pricing    |                           |
|                   | support analysts in  |                           |
|                   | support of these     |                           |
|                   | activities.          |                           |
|                   | Additional           |                           |
|                   | supporting           |                           |
|                   | documentation for    |                           |
|                   | large competitive    |                           |
|                   | acquisitions         |                           |
|                   | indicated that       |                           |
|                   | policies and         |                           |
|                   | procedures had been  |                           |
|                   | followed and that    |                           |
|                   | each step was        |                           |
|                   | thoroughly           |                           |
|                   | documented. This     |                           |
|                   | documentation        |                           |
|                   | provided an          |                           |
|                   | acceptable audit     |                           |
|                   | trail from           |                           |
|                   | acquisition planning |                           |
|                   | through final award. |                           |
|                   | In addition, source  |                           |
|                   | selection            |                           |
|                   | statements, which    |                           |
|                   | considered the       |                           |
|                   | findings of the      |                           |
|                   | board, were          |                           |
|                   | thorough, well       |                           |
|                   | documented, and      |                           |
|                   | provided clear       |                           |
|                   | rationale for the    |                           |
|                   | basis of selection.  |                           |
+-------------------+----------------------+---------------------------+
| **13.             |                      |                           |
| Pre-Negotiation   |                      |                           |
| and Post-         |                      |                           |
| Negotiation       |                      |                           |
| Documentation**   |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | emphasize the        |                           |
|                   | importance of        |                           |
|                   | adequate             |                           |
|                   | documentation to     |                           |
|                   | contracting          |                           |
|                   | specialists and      |                           |
|                   | officers. PPM and    |                           |
|                   | PNM files should     |                           |
|                   | contain all          |                           |
|                   | supporting           |                           |
|                   | documents. The file  |                           |
|                   | documentation should |                           |
|                   | be comprehensive,    |                           |
|                   | including proposed   |                           |
|                   | subcontractors and   |                           |
|                   | adequate narrative   |                           |
|                   | rationale. **(C)**   |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | emphasize the        |                           |
|                   | development of both  |                           |
|                   | an objective and     |                           |
|                   | maximum in           |                           |
|                   | circumstances where  |                           |
|                   | two negotiation      |                           |
|                   | positions for cost   |                           |
|                   | elements and the     |                           |
|                   | profit/fee may be    |                           |
|                   | appropriate.         |                           |
|                   | (Reference PIC       |                           |
|                   | 00-04) (W)           |                           |
+-------------------+----------------------+---------------------------+
| **14. Technical   |                      |                           |
| Evaluations**     |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | consider including   |                           |
|                   | language in          |                           |
|                   | solicitations that   |                           |
|                   | requires the offeror |                           |
|                   | or contractor to     |                           |
|                   | provide a proposal   |                           |
|                   | that time phases the |                           |
|                   | resources and        |                           |
|                   | pricing data by      |                           |
|                   | year. The            |                           |
|                   | utilization of       |                           |
|                   | templates with       |                           |
|                   | specific             |                           |
|                   | instructions to      |                           |
|                   | capture the required |                           |
|                   | data are helpful,    |                           |
|                   | provides consistency |                           |
|                   | across proposals and |                           |
|                   | allows the technical |                           |
|                   | evaluators to        |                           |
|                   | receive the          |                           |
|                   | appropriate type of  |                           |
|                   | data and information |                           |
|                   | necessary to perform |                           |
|                   | quality technical    |                           |
|                   | evaluations. **(C)** |                           |
+-------------------+----------------------+---------------------------+
|                   | b\. Goddard          |                           |
|                   | Procurement managers |                           |
|                   | should consider      |                           |
|                   | developing a         |                           |
|                   | standard technical   |                           |
|                   | evaluation request   |                           |
|                   | template that        |                           |
|                   | includes at a        |                           |
|                   | minimum the FAR      |                           |
|                   | requirements. The    |                           |
|                   | standard request     |                           |
|                   | template should also |                           |
|                   | state that the       |                           |
|                   | evaluation needs to  |                           |
|                   | reflect an analysis  |                           |
|                   | of the proposed      |                           |
|                   | hours and skill mix  |                           |
|                   | from a time phase    |                           |
|                   | perspective.         |                           |
|                   | Additionally, the    |                           |
|                   | standard request     |                           |
|                   | template should      |                           |
|                   | emphasize that       |                           |
|                   | written              |                           |
|                   | documentation        |                           |
|                   | accompany the        |                           |
|                   | analytical           |                           |
|                   | approaches and       |                           |
|                   | results of the       |                           |
|                   | evaluation. Finally, |                           |
|                   | the contract         |                           |
|                   | specialist should be |                           |
|                   | allowed to amend the |                           |
|                   | standard template    |                           |
|                   | with additional or   |                           |
|                   | specific areas such  |                           |
|                   | as facilities,       |                           |
|                   | equipment, training, |                           |
|                   | consultants, etc.,   |                           |
|                   | as appropriate.      |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | c\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | consider not only    |                           |
|                   | sending the request  |                           |
|                   | to the technical     |                           |
|                   | evaluator but also   |                           |
|                   | meeting with the     |                           |
|                   | evaluators to        |                           |
|                   | discuss technical    |                           |
|                   | issues and concerns  |                           |
|                   | prior to             |                           |
|                   | negotiations. Direct |                           |
|                   | communication        |                           |
|                   | between the          |                           |
|                   | procurement and      |                           |
|                   | technical            |                           |
|                   | representatives      |                           |
|                   | ensures that: a) the |                           |
|                   | technical community  |                           |
|                   | understands the      |                           |
|                   | objective of the     |                           |
|                   | action and increases |                           |
|                   | the quality of the   |                           |
|                   | analysis and         |                           |
|                   | documentation and b) |                           |
|                   | the procurement      |                           |
|                   | professional         |                           |
|                   | receives the         |                           |
|                   | necessary data to    |                           |
|                   | develop negotiation  |                           |
|                   | positions. **(C)**   |                           |
+-------------------+----------------------+---------------------------+
|                   | d\. Goddard          |                           |
|                   | Procurement managers |                           |
|                   | should ensure that   |                           |
|                   | emphasis is placed   |                           |
|                   | on the content and   |                           |
|                   | quality of technical |                           |
|                   | evaluations by both  |                           |
|                   | procurement and      |                           |
|                   | technical            |                           |
|                   | professionals.       |                           |
|                   | Managers should      |                           |
|                   | ensure that contract |                           |
|                   | specialists and      |                           |
|                   | contracting officers |                           |
|                   | are familiar with    |                           |
|                   | the pertinent FAR    |                           |
|                   | requirements and     |                           |
|                   | that the appropriate |                           |
|                   | information is       |                           |
|                   | included in the      |                           |
|                   | request for          |                           |
|                   | technical            |                           |
|                   | evaluations (see     |                           |
|                   | consideration).      |                           |
|                   | Procurement          |                           |
|                   | personnel should     |                           |
|                   | also ensure that the |                           |
|                   | quality of the       |                           |
|                   | technical evaluation |                           |
|                   | is consistent with   |                           |
|                   | the financial risk   |                           |
|                   | and complexity       |                           |
|                   | associated with the  |                           |
|                   | procurement action.  |                           |
|                   | Follow-up measures   |                           |
|                   | should be taken if   |                           |
|                   | the appropriate      |                           |
|                   | technical input is   |                           |
|                   | not received. (W)    |                           |
+-------------------+----------------------+---------------------------+
|                   | e\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that the      |                           |
|                   | technical evaluators |                           |
|                   | comply with the      |                           |
|                   | technical evaluation |                           |
|                   | request. All         |                           |
|                   | critical and         |                           |
|                   | significant areas    |                           |
|                   | should be evaluated  |                           |
|                   | with analytical      |                           |
|                   | approaches to        |                           |
|                   | determine if the     |                           |
|                   | proposed resources   |                           |
|                   | are consistent with  |                           |
|                   | the proposed         |                           |
|                   | approach. The        |                           |
|                   | evaluation should    |                           |
|                   | include supporting   |                           |
|                   | rationale for        |                           |
|                   | technical            |                           |
|                   | determinations.      |                           |
|                   | Sufficient           |                           |
|                   | documentation should |                           |
|                   | be provided in       |                           |
|                   | narrative form to    |                           |
|                   | allow the contract   |                           |
|                   | specialist adequate  |                           |
|                   | insight to develop   |                           |
|                   | negotiation          |                           |
|                   | positions. **(REPEAT |                           |
|                   | FINDING) (W)**       |                           |
+-------------------+----------------------+---------------------------+
| **15. Contractor  |                      |                           |
| Safety            |                      |                           |
| Requirements**    |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** All of the    |                           |
|                   | files that were      |                           |
|                   | reviewed contained   |                           |
|                   | the Goddard          |                           |
|                   | Initiator\'s         |                           |
|                   | Acquisition Safety   |                           |
|                   | Checklist for        |                           |
|                   | Procurements Form    |                           |
|                   | and the required     |                           |
|                   | 1852.223-75 clause.  |                           |
|                   | Every Goddard        |                           |
|                   | Initiator\'s         |                           |
|                   | Acquisition Safety   |                           |
|                   | Checklist reviewed   |                           |
|                   | was approved by the  |                           |
|                   | Safety and           |                           |
|                   | Environmental        |                           |
|                   | Branch. Overall, all |                           |
|                   | the reviewed files   |                           |
|                   | contained the        |                           |
|                   | required safety and  |                           |
|                   | health clauses and,  |                           |
|                   | if applicable, the   |                           |
|                   | approved             |                           |
|                   | contractor's safety  |                           |
|                   | and health plan.     |                           |
+-------------------+----------------------+---------------------------+
| **16. Contractor  |                      |                           |
| Performance       |                      |                           |
| Evaluation**      |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement Officer  |                           |
|                   | should ensure that   |                           |
|                   | contracting officers |                           |
|                   | comply with the FAR  |                           |
|                   | and NFS requirements |                           |
|                   | regarding contractor |                           |
|                   | performance          |                           |
|                   | evaluations,         |                           |
|                   | including meeting    |                           |
|                   | the 60-day lead time |                           |
|                   | for completion of    |                           |
|                   | the evaluation, and  |                           |
|                   | providing            |                           |
|                   | substantive          |                           |
|                   | narrative to justify |                           |
|                   | the ratings. (**C)** |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Headquarters  |                           |
|                   | Office of            |                           |
|                   | Procurement should   |                           |
|                   | establish a          |                           |
|                   | mechanism that       |                           |
|                   | alerts the contract  |                           |
|                   | specialist to ensure |                           |
|                   | that they are        |                           |
|                   | informed that the    |                           |
|                   | data in PPDB was not |                           |
|                   | posted as complete   |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **17.             |                      |                           |
| Award/Incentive   |                      |                           |
| Fee Evaluation**  |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a\. Goddard          |                           |
|                   | Procurement is       |                           |
|                   | commended for        |                           |
|                   | improving the timely |                           |
|                   | completion and       |                           |
|                   | approval of award    |                           |
|                   | fee plans and the    |                           |
|                   | effective execution  |                           |
|                   | of the award fee     |                           |
|                   | process. As a result |                           |
|                   | of these efforts,    |                           |
|                   | the average days     |                           |
|                   | late for PEBs and    |                           |
|                   | FDO Letters has      |                           |
|                   | decreased from       |                           |
|                   | approximately        |                           |
|                   | fifteen days to      |                           |
|                   | approximately five   |                           |
|                   | days (S).            |                           |
+-------------------+----------------------+---------------------------+
|                   | b\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that the cost |                           |
|                   | benefit analysis     |                           |
|                   | developed for the    |                           |
|                   | establishment of     |                           |
|                   | award fee contracts  |                           |
|                   | identifies all       |                           |
|                   | administrative costs |                           |
|                   | (including the costs |                           |
|                   | of all personnel     |                           |
|                   | assigned to the PEB, |                           |
|                   | procurement          |                           |
|                   | personnel and other  |                           |
|                   | staff as             |                           |
|                   | appropriate). It     |                           |
|                   | should also capture  |                           |
|                   | the cost of time     |                           |
|                   | spent by all         |                           |
|                   | personnel performing |                           |
|                   | the additional       |                           |
|                   | responsibilities     |                           |
|                   | required by the PEB  |                           |
|                   | to provide a         |                           |
|                   | reasonable basis for |                           |
|                   | assessing the        |                           |
|                   | relative value of    |                           |
|                   | the award fee        |                           |
|                   | process **(C)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | c\. The Goddard      |                           |
|                   | Procurement Officer  |                           |
|                   | should ensure that   |                           |
|                   | pre-award contract   |                           |
|                   | files contain        |                           |
|                   | documentation        |                           |
|                   | required by NFS and  |                           |
|                   | Goddard Policy       |                           |
|                   | concerning the       |                           |
|                   | selection of award   |                           |
|                   | fee contracts.       |                           |
|                   | (**W)**              |                           |
+-------------------+----------------------+---------------------------+
| **18. Closeout    |                      |                           |
| and Unliquidated  |                      |                           |
| Obligations       |                      |                           |
| (ULOs)**          |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The Goddard   |                           |
|                   | Procurement Officer  |                           |
|                   | is commended for     |                           |
|                   | establishing a       |                           |
|                   | strong relationship  |                           |
|                   | with the Finance     |                           |
|                   | organization and     |                           |
|                   | working as a team to |                           |
|                   | reconcile and reduce |                           |
|                   | the number of        |                           |
|                   | records awaiting     |                           |
|                   | closeout and         |                           |
|                   | reducing the dollar  |                           |
|                   | amount of            |                           |
|                   | undisbursed          |                           |
|                   | obligations. The     |                           |
|                   | initiation of the    |                           |
|                   | Corrective Action    |                           |
|                   | Plan is also a       |                           |
|                   | positive **(S)**     |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.**. The          |                           |
|                   | close-out            |                           |
|                   | contractor's         |                           |
|                   | procedure to         |                           |
|                   | maintain records of  |                           |
|                   | all actions taken    |                           |
|                   | and the ability to   |                           |
|                   | provide a report     |                           |
|                   | upon request to the  |                           |
|                   | cognizant            |                           |
|                   | contracting officer  |                           |
|                   | or systems team      |                           |
|                   | member provides      |                           |
|                   | timely insight into  |                           |
|                   | close-out activities |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** Goddard       |                           |
|                   | Procurement is       |                           |
|                   | commended for taking |                           |
|                   | the initiative to    |                           |
|                   | successfully work    |                           |
|                   | with the system      |                           |
|                   | interface            |                           |
|                   | limitations in the   |                           |
|                   | processing of        |                           |
|                   | simplified           |                           |
|                   | acquisition          |                           |
|                   | closeouts in CMM.    |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **d.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | continue to take     |                           |
|                   | steps to reduce the  |                           |
|                   | significant volume   |                           |
|                   | of files (over       |                           |
|                   | 14,000) awaiting     |                           |
|                   | closeout. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
| **19.             |                      |                           |
| Undefinitized     |                      |                           |
| Contract Actions  |                      |                           |
| (UCAs)**          |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | is commended for the |                           |
|                   | reduction in the     |                           |
|                   | number of UCAs from  |                           |
|                   | the previous survey. |                           |
|                   | and successfully     |                           |
|                   | definitizing their   |                           |
|                   | open UCAs within 180 |                           |
|                   | days **(S)**         |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** Goddard       |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | should ensure that   |                           |
|                   | the proper cost      |                           |
|                   | analysis is          |                           |
|                   | performed when       |                           |
|                   | implementing the     |                           |
|                   | modification to      |                           |
|                   | definitize UCAs.     |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **20. Competition |                      |                           |
| under Multiple    |                      |                           |
| Award Task and    |                      |                           |
| Delivery Order    |                      |                           |
| Contracts**       |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a\. The Goddard      |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | should ensure that   |                           |
|                   | GSA Single Award BPA |                           |
|                   | files document the   |                           |
|                   | determination to     |                           |
|                   | establish a single   |                           |
|                   | BPA (File Tab 9) in  |                           |
|                   | accordance with the  |                           |
|                   | guidance provided in |                           |
|                   | FAR 8.405-3(a)(1).   |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | b\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | consider modifying   |                           |
|                   | the Summary of       |                           |
|                   | Quotation/Selection  |                           |
|                   | form to include a    |                           |
|                   | section that         |                           |
|                   | reflects all vendors |                           |
|                   | in a category. A     |                           |
|                   | section with an      |                           |
|                   | option to select a   |                           |
|                   | particular category  |                           |
|                   | and inclusion of a   |                           |
|                   | copy of the RFQ      |                           |
|                   | displaying all       |                           |
|                   | vendors may be       |                           |
|                   | helpful. **(C)**     |                           |
+-------------------+----------------------+---------------------------+
| **21. Options to  |                      |                           |
| Extend            |                      |                           |
| Performance**     |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Although      |                           |
|                   | improvement in       |                           |
|                   | documentation is     |                           |
|                   | noted since the last |                           |
|                   | survey, areas of     |                           |
|                   | concern are still    |                           |
|                   | present. The Goddard |                           |
|                   | Procurement Officer  |                           |
|                   | should remind        |                           |
|                   | contracting officers |                           |
|                   | to sign and date     |                           |
|                   | documents in the     |                           |
|                   | files when they are  |                           |
|                   | prepared. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** . The Goddard |                           |
|                   | Procurement Officer  |                           |
|                   | should ensure that   |                           |
|                   | contracting officers |                           |
|                   | document the         |                           |
|                   | analysis supporting  |                           |
|                   | the determination to |                           |
|                   | exercise the option  |                           |
|                   | prior to providing   |                           |
|                   | notice to the        |                           |
|                   | contractor and that  |                           |
|                   | contracting officers |                           |
|                   | execute the option   |                           |
|                   | modification before  |                           |
|                   | the option period    |                           |
|                   | begins. **(C)**      |                           |
+-------------------+----------------------+---------------------------+
| **22. Government  |                      |                           |
| Furnished         |                      |                           |
| Property**        |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The           |                           |
|                   | Procurement Officer  |                           |
|                   | is commended for the |                           |
|                   | relationship         |                           |
|                   | developed and        |                           |
|                   | maintained with the  |                           |
|                   | SEMO office. **(S)** |                           |
+-------------------+----------------------+---------------------------+
| **23. COTR        |                      |                           |
| Delegations and   |                      |                           |
| Contractor        |                      |                           |
| Surveillance**    |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | ensure that COTR     |                           |
|                   | delegations are      |                           |
|                   | issued in a timely   |                           |
|                   | manner and that all  |                           |
|                   | files contain a COTR |                           |
|                   | delegation in        |                           |
|                   | accordance with NFS  |                           |
|                   | 1842.270. **(W)**    |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | ensure that all COTR |                           |
|                   | delegations (NF      |                           |
|                   | 1634) requiring      |                           |
|                   | surveillance plans   |                           |
|                   | and contractor       |                           |
|                   | surveillance include |                           |
|                   | the appropriate      |                           |
|                   | documentation in the |                           |
|                   | file as well as      |                           |
|                   | evidence of          |                           |
|                   | surveillance. If     |                           |
|                   | surveillance plans   |                           |
|                   | are not required,    |                           |
|                   | COTR delegations     |                           |
|                   | should be modified   |                           |
|                   | accordingly (**W)**  |                           |
+-------------------+----------------------+---------------------------+
| **24. Financial   |                      |                           |
| Management        |                      |                           |
| Reporting**       |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement is       |                           |
|                   | commended for the    |                           |
|                   | incorporation of the |                           |
|                   | checklist to         |                           |
|                   | document analysis of |                           |
|                   | financial management |                           |
|                   | reports. The         |                           |
|                   | checklist appears to |                           |
|                   | be a controlled      |                           |
|                   | internal document    |                           |
|                   | (Goddard Form        |                           |
|                   | 210-49). The         |                           |
|                   | checklist is         |                           |
|                   | comprehensive in     |                           |
|                   | nature and acts as a |                           |
|                   | good reminder to the |                           |
|                   | contracting          |                           |
|                   | professional that    |                           |
|                   | they must perform a  |                           |
|                   | review. **(S)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement          |                           |
|                   | management should    |                           |
|                   | remind procurement   |                           |
|                   | professionals that   |                           |
|                   | narrative rationale  |                           |
|                   | must accompany the   |                           |
|                   | Form 210-49 when     |                           |
|                   | variances between    |                           |
|                   | planned and actual   |                           |
|                   | expenditures exist.  |                           |
|                   | Variances should be  |                           |
|                   | adequately           |                           |
|                   | documented and       |                           |
|                   | resolved. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
| **25. DCAA/OIG    |                      |                           |
| Audit Follow-up** |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | implement a process  |                           |
|                   | to track and monitor |                           |
|                   | system level audits  |                           |
|                   | on a quarterly or    |                           |
|                   | semi-annual basis to |                           |
|                   | ensure that they are |                           |
|                   | closed in a timely   |                           |
|                   | manner and that      |                           |
|                   | closure notices are  |                           |
|                   | sent to the          |                           |
|                   | appropriate Agency.  |                           |
|                   | The process does not |                           |
|                   | have to be overly    |                           |
|                   | complicated or       |                           |
|                   | burdensome and can   |                           |
|                   | be achieved using an |                           |
|                   | Excel spreadsheet.   |                           |
|                   | **(REPEAT            |                           |
|                   | FINDING)**. **(C)**  |                           |
+-------------------+----------------------+---------------------------+
| **26. Cost/Price  |                      |                           |
| Analysis**        |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | ensure that price    |                           |
|                   | analyses are         |                           |
|                   | performed on         |                           |
|                   | procurement actions  |                           |
|                   | when appropriate.    |                           |
|                   | Although price       |                           |
|                   | analysis is only     |                           |
|                   | required when cost   |                           |
|                   | or pricing data is   |                           |
|                   | required, this type  |                           |
|                   | of analysis is very  |                           |
|                   | effective in         |                           |
|                   | validating price     |                           |
|                   | reasonableness.      |                           |
|                   | Goddard Procurement  |                           |
|                   | should consider      |                           |
|                   | performing price     |                           |
|                   | analysis on actions  |                           |
|                   | where cost analysis  |                           |
|                   | may not suffice      |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b**. Goddard       |                           |
|                   | Procurement should   |                           |
|                   | consider             |                           |
|                   | establishing a       |                           |
|                   | process for the SEB  |                           |
|                   | to have traceability |                           |
|                   | between the probable |                           |
|                   | cost adjustments and |                           |
|                   | the mission          |                           |
|                   | suitability          |                           |
|                   | findings. This will  |                           |
|                   | ensure that the all  |                           |
|                   | mission suitability  |                           |
|                   | findings result in   |                           |
|                   | appropriate probable |                           |
|                   | cost adjustments.    |                           |
|                   | Also consider        |                           |
|                   | performing an        |                           |
|                   | analysis of proposed |                           |
|                   | indirect rates and   |                           |
|                   | ceiling rates to     |                           |
|                   | determine whether    |                           |
|                   | probable cost        |                           |
|                   | adjustments up to    |                           |
|                   | the ceiling are      |                           |
|                   | appropriate.         |                           |
|                   | Further, consider    |                           |
|                   | requiring the        |                           |
|                   | contractor to        |                           |
|                   | provide previous     |                           |
|                   | contract actual      |                           |
|                   | experience on this   |                           |
|                   | subject as well as   |                           |
|                   | request DCAA to      |                           |
|                   | provide insight, if  |                           |
|                   | available. **(C)**   |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | consider reviewing   |                           |
|                   | Cost and Price       |                           |
|                   | Analysis in future   |                           |
|                   | self assessments     |                           |
|                   | particularly since   |                           |
|                   | this area has had    |                           |
|                   | weaknesses in the    |                           |
|                   | past. The focus      |                           |
|                   | should be on         |                           |
|                   | reliance of cost or  |                           |
|                   | pricing data,        |                           |
|                   | utilization and      |                           |
|                   | disposition of DCAA  |                           |
|                   | audit findings,      |                           |
|                   | independent cost     |                           |
|                   | analysis of prime    |                           |
|                   | and subcontractors,  |                           |
|                   | utilization of price |                           |
|                   | analysis and         |                           |
|                   | adequate             |                           |
|                   | d                    |                           |
|                   | ocumentation.**(C)** |                           |
+-------------------+----------------------+---------------------------+
|                   | **d.** The Goddard   |                           |
|                   | Procurement Officer  |                           |
|                   | should ensure that   |                           |
|                   | contracting          |                           |
|                   | personnel perform an |                           |
|                   | independent cost     |                           |
|                   | analysis of the cost |                           |
|                   | proposal rather than |                           |
|                   | totally rely on the  |                           |
|                   | DCAA audit to        |                           |
|                   | satisfy the          |                           |
|                   | requirement for      |                           |
|                   | performing cost      |                           |
|                   | analysis. The audits |                           |
|                   | are usually focused  |                           |
|                   | on rates and factors |                           |
|                   | and do not perform   |                           |
|                   | cost analysis. They  |                           |
|                   | also do not perform  |                           |
|                   | a technical analysis |                           |
|                   | so are not           |                           |
|                   | intimately familiar  |                           |
|                   | with the technical   |                           |
|                   | requirements.        |                           |
|                   | Requirements and     |                           |
|                   | associated resources |                           |
|                   | (labor, materials,   |                           |
|                   | equipment, etc) may  |                           |
|                   | affect the           |                           |
|                   | development of       |                           |
|                   | rates, particularly  |                           |
|                   | if the procurement   |                           |
|                   | is sizeable. In      |                           |
|                   | order to develop     |                           |
|                   | adequate negotiation |                           |
|                   | positions, the need  |                           |
|                   | for comprehensive    |                           |
|                   | cost analysis is     |                           |
|                   | required. This       |                           |
|                   | includes             |                           |
|                   | incorporating the    |                           |
|                   | DCAA results along   |                           |
|                   | with an independent  |                           |
|                   | critical cost        |                           |
|                   | analysis and should  |                           |
|                   | leverage from        |                           |
|                   | relevant in-house    |                           |
|                   | historical           |                           |
|                   | experience and/or    |                           |
|                   | legacy systems       |                           |
|                   | knowledge. **(REPEAT |                           |
|                   | FINDING)** (**W**)   |                           |
+-------------------+----------------------+---------------------------+
| **27. Structured  |                      |                           |
| Fee Approach (NF  |                      |                           |
| 634)**            |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | consider writing the |                           |
|                   | justification in a   |                           |
|                   | manner that          |                           |
|                   | addresses            |                           |
|                   | performance risk as  |                           |
|                   | each area is         |                           |
|                   | documented. The      |                           |
|                   | Goddard Procurement  |                           |
|                   | review team should   |                           |
|                   | consider reviewing   |                           |
|                   | NF 634 analysis and  |                           |
|                   | documentation to     |                           |
|                   | ensure that the      |                           |
|                   | rationale addresses  |                           |
|                   | performance risk and |                           |
|                   | the rationale        |                           |
|                   | adequately provides  |                           |
|                   | the basis for using  |                           |
|                   | the values/weights.  |                           |
|                   | Including written    |                           |
|                   | rationale shows a    |                           |
|                   | positive in pencil.  |                           |
|                   | . **(C)**            |                           |
+-------------------+----------------------+---------------------------+
|                   | b\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that the NF   |                           |
|                   | 634 is created       |                           |
|                   | electronically to    |                           |
|                   | facilitate           |                           |
|                   | performing the       |                           |
|                   | analysis             |                           |
|                   | electronically and   |                           |
|                   | avoiding potential   |                           |
|                   | errors. **(C)**      |                           |
+-------------------+----------------------+---------------------------+
| **28. Grants and  |                      |                           |
| Cooperative       |                      |                           |
| Agreements**      |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The           |                           |
|                   | Headquarters         |                           |
|                   | Sponsored Research   |                           |
|                   | Business Activity    |                           |
|                   | should ensure that   |                           |
|                   | the Grants Handbook  |                           |
|                   | is updated to        |                           |
|                   | identify procedures  |                           |
|                   | for documenting the  |                           |
|                   | review of the        |                           |
|                   | proposer's estimated |                           |
|                   | costs. The           |                           |
|                   | documentation should |                           |
|                   | reflect information  |                           |
|                   | from cost proposals  |                           |
|                   | for NRAs and         |                           |
|                   | unsolicited          |                           |
|                   | proposals that is    |                           |
|                   | not submitted on the |                           |
|                   | Budget Summary Form  |                           |
|                   | currently included   |                           |
|                   | in the Grants        |                           |
|                   | Handbook. **(C)**    |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | ensure that all      |                           |
|                   | unsolicited          |                           |
|                   | proposals qualify    |                           |
|                   | for award in         |                           |
|                   | accordance with the  |                           |
|                   | FAR requirements.    |                           |
|                   | **(W)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | c\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that all      |                           |
|                   | grants files include |                           |
|                   | a detailed analysis  |                           |
|                   | of the proposed      |                           |
|                   | costs **(W)**        |                           |
+-------------------+----------------------+---------------------------+
| **29. Simplified  |                      |                           |
| Acquis            |                      |                           |
| itions/Commercial |                      |                           |
| Item              |                      |                           |
| Procurement**     |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | take steps to        |                           |
|                   | improve the overall  |                           |
|                   | quality of the       |                           |
|                   | simplified           |                           |
|                   | acquisition files,   |                           |
|                   | specifically in the  |                           |
|                   | areas of sole source |                           |
|                   | justifications and   |                           |
|                   | price analysis.      |                           |
|                   | Additionally,        |                           |
|                   | Goddard Procurement  |                           |
|                   | should ensure that   |                           |
|                   | contracting          |                           |
|                   | personnel receive    |                           |
|                   | the necessary        |                           |
|                   | training and         |                           |
|                   | oversight regarding  |                           |
|                   | file documentation   |                           |
|                   | and analysis.        |                           |
|                   | **(REPEAT FINDING)   |                           |
|                   | (W)**                |                           |
+-------------------+----------------------+---------------------------+
| **30.             |                      |                           |
| Inter-Agency      |                      |                           |
| Agreements**      |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard is    |                           |
|                   | commended for        |                           |
|                   | developing standard  |                           |
|                   | formats for          |                           |
|                   | Interagency          |                           |
|                   | Acquisitions and     |                           |
|                   | D&Fs within the      |                           |
|                   | individual offices   |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | standardize IA       |                           |
|                   | documentation across |                           |
|                   | the entire           |                           |
|                   | organization rather  |                           |
|                   | than within          |                           |
|                   | individual offices.  |                           |
|                   | Review at a level    |                           |
|                   | above the            |                           |
|                   | contracting officer  |                           |
|                   | completing the       |                           |
|                   | action could help to |                           |
|                   | achieve              |                           |
|                   | standardization of   |                           |
|                   | documentation and    |                           |
|                   | would seem prudent   |                           |
|                   | as a risk management |                           |
|                   | tool given the size  |                           |
|                   | of many of the IA    |                           |
|                   | actions. Goddard     |                           |
|                   | Procurement should   |                           |
|                   | also consider        |                           |
|                   | working with         |                           |
|                   | Headquarters Offices |                           |
|                   | to ensure more       |                           |
|                   | timely receipt of IA |                           |
|                   | purchase requests to |                           |
|                   | minimize the need to |                           |
|                   | place orders after   |                           |
|                   | the initiation of    |                           |
|                   | performance by the   |                           |
|                   | agency. Goddard      |                           |
|                   | Procurement should   |                           |
|                   | also comply with the |                           |
|                   | requirement that all |                           |
|                   | IAs be completed on  |                           |
|                   | NASA form 523 (vs.   |                           |
|                   | Optional Form 347).  |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | re-assess the        |                           |
|                   | procedures used to   |                           |
|                   | ensure that adequate |                           |
|                   | competition is       |                           |
|                   | obtained for GSA     |                           |
|                   | orders. **(C)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | d\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that          |                           |
|                   | sufficient rationale |                           |
|                   | is provided in the   |                           |
|                   | determination and    |                           |
|                   | finding to justify   |                           |
|                   | placement of the     |                           |
|                   | order in lieu of an  |                           |
|                   | outside award for    |                           |
|                   | the required         |                           |
|                   | services.            |                           |
|                   | Additionally,        |                           |
|                   | sufficient cost      |                           |
|                   | analysis should be   |                           |
|                   | performed for effort |                           |
|                   | proposed by the      |                           |
|                   | government agency    |                           |
|                   | and cost-breakdown   |                           |
|                   | of any effort        |                           |
|                   | proposed by outside  |                           |
|                   | organizations should |                           |
|                   | be provided for      |                           |
|                   | analysis and review. |                           |
|                   | (W)                  |                           |
+-------------------+----------------------+---------------------------+
|                   | e\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that          |                           |
|                   | determination and    |                           |
|                   | findings are         |                           |
|                   | reviewed by legal    |                           |
|                   | counsel as required  |                           |
|                   | by the NFS. It is    |                           |
|                   | particularly         |                           |
|                   | important that       |                           |
|                   | reviews are          |                           |
|                   | conducted at a level |                           |
|                   | above the cognizant  |                           |
|                   | contracting officer, |                           |
|                   | especially with the  |                           |
|                   | large number of high |                           |
|                   | dollar value         |                           |
|                   | requirements and the |                           |
|                   | potential for work   |                           |
|                   | performed by         |                           |
|                   | organizations        |                           |
|                   | (outside             |                           |
|                   | contractors) other   |                           |
|                   | than the servicing   |                           |
|                   | Agency (W)           |                           |
+-------------------+----------------------+---------------------------+
| **31. Purchase    |                      |                           |
| Card Program**    |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement is       |                           |
|                   | commended for        |                           |
|                   | performing an        |                           |
|                   | internal desk audit  |                           |
|                   | of all existing      |                           |
|                   | purchase card        |                           |
|                   | cardholders, this    |                           |
|                   | audit                |                           |
|                   | reviewed/verified    |                           |
|                   | several              |                           |
|                   | transactions,        |                           |
|                   | receipts, and        |                           |
|                   | supporting           |                           |
|                   | documentation that   |                           |
|                   | occurred over the    |                           |
|                   | past three (3)       |                           |
|                   | years. Also, the     |                           |
|                   | CAPC and alternate   |                           |
|                   | are available to     |                           |
|                   | program users        |                           |
|                   | through the Center   |                           |
|                   | purchase card phone  |                           |
|                   | help-line to discuss |                           |
|                   | problems, provide    |                           |
|                   | guidance, and        |                           |
|                   | provide              |                           |
|                   | clarification on a   |                           |
|                   | variety of issues.   |                           |
|                   | In addition, Goddard |                           |
|                   | Procurement provides |                           |
|                   | an outstanding       |                           |
|                   | website that         |                           |
|                   | contains extensive   |                           |
|                   | information such as  |                           |
|                   | the user's guide,    |                           |
|                   | instructions on      |                           |
|                   | specific bankcard    |                           |
|                   | issues,              |                           |
|                   | responsibilities,    |                           |
|                   | and many other areas |                           |
|                   | . **(S)**            |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** The Goddard   |                           |
|                   | Procurement Officer  |                           |
|                   | should carefully     |                           |
|                   | monitor the          |                           |
|                   | re-certification     |                           |
|                   | program and take the |                           |
|                   | necessary steps to   |                           |
|                   | ensure that all      |                           |
|                   | required purchase    |                           |
|                   | card holders         |                           |
|                   | complete the         |                           |
|                   | refresher training   |                           |
|                   | in a timely manner.  |                           |
|                   | **(REPEAT FINDING)   |                           |
|                   | (C)**                |                           |
+-------------------+----------------------+---------------------------+
| **32.             |                      |                           |
| Construction and  |                      |                           |
| Architect and     |                      |                           |
| Engineer (A&E)    |                      |                           |
| Contracts**       |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.                 |                           |
|                   | (Construction)**     |                           |
|                   | Goddard Procurement  |                           |
|                   | should ensure that   |                           |
|                   | performance and      |                           |
|                   | payment bonds are    |                           |
|                   | increased if the     |                           |
|                   | total contract value |                           |
|                   | is increased.        |                           |
|                   | **(W)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.                 |                           |
|                   | (Construction)**     |                           |
|                   | Goddard Procurement  |                           |
|                   | should ensure that   |                           |
|                   | Safety Plans are     |                           |
|                   | coordinated and      |                           |
|                   | documented with      |                           |
|                   | approval from the    |                           |
|                   | Safety Office.       |                           |
|                   | Safety Plans should  |                           |
|                   | be incorporated into |                           |
|                   | the contracts by     |                           |
|                   | modification after   |                           |
|                   | award and before     |                           |
|                   | Notice to Proceed is |                           |
|                   | issued.. **(C)**     |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.                 |                           |
|                   | (Construction)**     |                           |
|                   | Goddard Procurement  |                           |
|                   | should extend the    |                           |
|                   | bond coverage if the |                           |
|                   | period of            |                           |
|                   | performance is       |                           |
|                   | extended in          |                           |
|                   | accordance with the  |                           |
|                   | modified contract    |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **d. (A&Es)**        |                           |
|                   | Goddard Procurement  |                           |
|                   | is commended for its |                           |
|                   | contract             |                           |
|                   | administration       |                           |
|                   | efforts on A&E       |                           |
|                   | contracts. Contract  |                           |
|                   | administration files |                           |
|                   | were well organized  |                           |
|                   | and contained        |                           |
|                   | detailed government  |                           |
|                   | estimates, technical |                           |
|                   | evaluations, and     |                           |
|                   | price negotiations   |                           |
|                   | memorandums. **(S)** |                           |
+-------------------+----------------------+---------------------------+
|                   | e\. (A&Es)Goddard    |                           |
|                   | Procurement should   |                           |
|                   | ensure that Safety   |                           |
|                   | Plans should be      |                           |
|                   | coordinated and      |                           |
|                   | documented with      |                           |
|                   | approval from the    |                           |
|                   | Safety Office.       |                           |
|                   | Safety Plans should  |                           |
|                   | be incorporated into |                           |
|                   | the contracts by     |                           |
|                   | modification after   |                           |
|                   | award and before     |                           |
|                   | Notice to Proceed is |                           |
|                   | issued. **(C)**      |                           |
+-------------------+----------------------+---------------------------+
|                   | **f. (A&Es)**        |                           |
|                   | Goddard Procurement  |                           |
|                   | should ensure that   |                           |
|                   | all proper FAR       |                           |
|                   | clauses for A&E are  |                           |
|                   | included in the      |                           |
|                   | so                   |                           |
|                   | licitation/contract. |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **33.             |                      |                           |
| Environmental     |                      |                           |
| Issues**          |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a\. Goddard          |                           |
|                   | Procurement should   |                           |
|                   | ensure that the NF   |                           |
|                   | 1707 is completed    |                           |
|                   | and maintained in    |                           |
|                   | the contract files.  |                           |
|                   | The Simplified       |                           |
|                   | Acquisition Contract |                           |
|                   | Checklist contains a |                           |
|                   | box to annotate the  |                           |
|                   | presence of the NF   |                           |
|                   | 1707**(C)**          |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Headquarters  |                           |
|                   | Office of            |                           |
|                   | Procurement should   |                           |
|                   | consider amending    |                           |
|                   | the NF 1098 -        |                           |
|                   | Checklist for        |                           |
|                   | Contract Award File  |                           |
|                   | Content to include   |                           |
|                   | the requirement for  |                           |
|                   | the NF 1707          |                           |
|                   | documentation        |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
| **34. Small       |                      |                           |
| Business          |                      |                           |
| Innovative        |                      |                           |
| Research (SBIR)   |                      |                           |
| Award**           |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** The NASA      |                           |
|                   | Headquarters Office  |                           |
|                   | of Procurement       |                           |
|                   | should research and  |                           |
|                   | resolve any          |                           |
|                   | ambiguity regarding  |                           |
|                   | the roles and        |                           |
|                   | responsibilities for |                           |
|                   | the development of   |                           |
|                   | policy guidance for  |                           |
|                   | SBIRs/STTRs. **(C)** |                           |
+-------------------+----------------------+---------------------------+
| **35. Metrics**   |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | a.The ULO tracking   |                           |
|                   | mechanism that was   |                           |
|                   | discussed in the     |                           |
|                   | previous survey has  |                           |
|                   | not been fully       |                           |
|                   | implemented.         |                           |
|                   | However, the Office  |                           |
|                   | of the Chief         |                           |
|                   | Financial Officer in |                           |
|                   | conjunction with     |                           |
|                   | Procurement          |                           |
|                   | Operations Division  |                           |
|                   | and the resources    |                           |
|                   | community are        |                           |
|                   | putting greater      |                           |
|                   | emphasis on the      |                           |
|                   | tracking of ULOs.    |                           |
|                   | There are several    |                           |
|                   | tools being used to  |                           |
|                   | track ULOs in        |                           |
|                   | particular there is  |                           |
|                   | a tool that          |                           |
|                   | currently tracks     |                           |
|                   | them by Procurement  |                           |
|                   | Line Item.           |                           |
+-------------------+----------------------+---------------------------+
| **36. Homeland    |                      |                           |
| Security Policy   |                      |                           |
| Directive (HSPD)  |                      |                           |
| -12 Compliance**  |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Goddard       |                           |
|                   | Procurement is       |                           |
|                   | commended on its     |                           |
|                   | proactive approach   |                           |
|                   | in working with the  |                           |
|                   | Goddard Security     |                           |
|                   | Office and other     |                           |
|                   | offices to implement |                           |
|                   | the HSPD-12 contract |                           |
|                   | requirements for     |                           |
|                   | onsite contractors   |                           |
|                   | and for working      |                           |
|                   | proactively with the |                           |
|                   | Center and           |                           |
|                   | Contractor community |                           |
|                   | to highlight the     |                           |
|                   | need to complete     |                           |
|                   | Personal Identity    |                           |
|                   | Verification (PIV)   |                           |
|                   | badging              |                           |
|                   | requirements.        |                           |
|                   | **(S)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **b.** Goddard       |                           |
|                   | Procurement should   |                           |
|                   | reassess the         |                           |
|                   | requirement for      |                           |
|                   | incorporation of     |                           |
|                   | HSPD-12 requirements |                           |
|                   | for all contracts    |                           |
|                   | whether or not       |                           |
|                   | initially determined |                           |
|                   | to include on-site   |                           |
|                   | Goddard performance  |                           |
|                   | per the LIST system. |                           |
|                   | Special              |                           |
|                   | consideration should |                           |
|                   | be taken to address  |                           |
|                   | contracts that       |                           |
|                   | require contractor   |                           |
|                   | access to            |                           |
|                   | information systems. |                           |
|                   | **(C)**              |                           |
+-------------------+----------------------+---------------------------+
|                   | **c.** Headquarters  |                           |
|                   | Office of            |                           |
|                   | Procurement and      |                           |
|                   | Office of Security   |                           |
|                   | and Program          |                           |
|                   | Protection (as       |                           |
|                   | necessary) should    |                           |
|                   | take more proactive  |                           |
|                   | measures to work     |                           |
|                   | with Goddard         |                           |
|                   | Procurement (and     |                           |
|                   | other Centers) to    |                           |
|                   | discuss policy       |                           |
|                   | implementation       |                           |
|                   | requirements such as |                           |
|                   | HSPD-12 prior to     |                           |
|                   | their unilateral     |                           |
|                   | imposition. (**C)**  |                           |
+-------------------+----------------------+---------------------------+
| **37. Contract    |                      |                           |
| Management Module |                      |                           |
| Issues**          |                      |                           |
+-------------------+----------------------+---------------------------+
|                   | **a.** Initial CMM   |                           |
|                   | training was         |                           |
|                   | completed with 162   |                           |
|                   | people trained. The  |                           |
|                   | training was generic |                           |
|                   | on the PRISM         |                           |
|                   | Software, not        |                           |
|                   | conducted in the     |                           |
|                   | integrated PRISM-SAP |                           |
|                   | environment.         |                           |
|                   | Numerous Service     |                           |
|                   | Requests (SRs) were  |                           |
|                   | applied to the CMM   |                           |
|                   | system immediately   |                           |
|                   | following go-live,   |                           |
|                   | during the           |                           |
|                   | stabilization        |                           |
|                   | period. The generic  |                           |
|                   | nature of the        |                           |
|                   | training combined    |                           |
|                   | with changes in the  |                           |
|                   | look and feel of the |                           |
|                   | system increased     |                           |
|                   | user frustration and |                           |
|                   | hindered             |                           |
|                   | familiarization. New |                           |
|                   | employees who have   |                           |
|                   | come on-board after  |                           |
|                   | the initial training |                           |
|                   | period have not had  |                           |
|                   | the opportunity or   |                           |
|                   | awareness of         |                           |
|                   | training on the CMM. |                           |
|                   | The Procurement      |                           |
|                   | System Support Team  |                           |
|                   | (PSST) provides      |                           |
|                   | one-on-one hands-on  |                           |
|                   | sessions to work     |                           |
|                   | with individual      |                           |
|                   | users. Feedback on   |                           |
|                   | the support provided |                           |
|                   | by the PSST has been |                           |
|                   | overwhelmingly       |                           |
|                   | positive.            |                           |
|                   | Specialists and      |                           |
|                   | Contracting Officers |                           |
|                   | specifically         |                           |
|                   | acknowledged the     |                           |
|                   | assistance provided  |                           |
|                   | by Steve Lloyd,      |                           |
|                   | Terry Keane, Nancy   |                           |
|                   | Lockard, and Wanda   |                           |
|                   | Behnke. A tip sheet  |                           |
|                   | has been developed,  |                           |
|                   | circulated, and      |                           |
|                   | periodically updated |                           |
|                   | to identify ways to  |                           |
|                   | work more            |                           |
|                   | effectively within   |                           |
|                   | the CMM system.      |                           |
+-------------------+----------------------+---------------------------+

+-----------------------------------+-----------------------------------+
| **Strength**                      | **Green**                         |
|                                   |                                   |
|                                   | **17**                            |
+-----------------------------------+-----------------------------------+
| **Weakness**                      | **Red**                           |
|                                   |                                   |
|                                   | **14**                            |
+-----------------------------------+-----------------------------------+
| **Consideration**                 | **Blue**                          |
|                                   |                                   |
|                                   | **43**                            |
+-----------------------------------+-----------------------------------+
| **Adequate**                      | **Black**                         |
|                                   |                                   |
|                                   | **7**                             |
+-----------------------------------+-----------------------------------+