![](media/image1.wmf){width="1.4013888888888888in"
height="1.2680555555555555in"}***NATIONAL AERONAUTICS AND***

***SPACE ADMINISTRATION***

**GSFC Procurement**

**Self-Assessment Survey Report**

GODDARD SPACE FLIGHT

CENTER

**April 2007**

# 

# Table of Contents 

# 

[Table of Contents 2](#table-of-contents)

[Introduction 3](#__RefHeading___Toc158446740)

[Methodology 3](#methodology)

[Review Team 3](#review-team)

[Scope of Review 4](#scope-of-review)

[SEMO REVIEWS](#__RefHeading___Toc158446744) 5

[**Findings**](#__RefHeading___Toc158446748) 5

[**Recommendations**](#__RefHeading___Toc158446745) 5

[INTERAGENCY ACQUISITION (IA\'s) STATEMENTS OF
WORK](#__RefHeading___Toc158446746) 6

[**Findings**](#__RefHeading___Toc158446748) 6

[**Recommendations**](#__RefHeading___Toc158446749) 6

[PRENEGOTIATIONS POSITION MEMORANDUM/PRICE NEGOTIATION MEMORANDUM
(PPM/PNM) DOCUMENTATION](#__RefHeading___Toc158446750) 8

[**Findings**](#__RefHeading___Toc158446751) 8

[**Recommendations**](#__RefHeading___Toc158446752) 9

[FEE RATIONALE (NF 634)](#__RefHeading___Toc158446753) 10

[**Findings**](#__RefHeading___Toc158446754) 10

[**Recommendations**](#__RefHeading___Toc158446755) 10

[TECHNICAL EVALUATIONS](#__RefHeading___Toc158446756) 11

[**Findings**](#__RefHeading___Toc158446757) 11

[**Recommendations**](#__RefHeading___Toc158446758) 11

SUBCONTRACT CONSENTS 12

SOLE SOURCE SIMPLIFIED ACQUISITIONS 13

[**Findings**](#__RefHeading___Toc158446757) 13

[**Recommendations**](#__RefHeading___Toc158446758) 13

[CONTRACTING OFFICER TECHNICAL REPRESENTATIVE (COTR)
CERTIFICATION](#__RefHeading___Toc158446756) 15

[**Findings**](#__RefHeading___Toc158446757) 15

[**Recommendations**](#__RefHeading___Toc158446758) 15

[NON-1102 WARRANTS/OTHER BUYING
AUTHORITIES](#__RefHeading___Toc158446756) 16

[**Findings**](#__RefHeading___Toc158446757) 16

[**Recommendations**](#__RefHeading___Toc158446758) 16

[ATTACHMENT TO THE SELF-ASSESSMENT REPORT
17](#attachment-a--overall-assessment-and-recommendations)

[Attachment A\--Overall Assessment And Recommendations
18](#attachment-a--overall-assessment-and-recommendations)

[]{#__RefHeading___Toc158446740 .anchor}**[Introduction]{.underline}**

Our survey team conducted a self-assessment survey of the procurement
function at The Goddard Space Flight Center (GSFC), which includes
procurement support for NASA Headquarters, the Wallops Flight Facility
(WFF), NASA\'s Independent Verification & Validation (IV&V) Facility,
and the Goddard Institute for Space Studies (GISS). This survey was
conducted using the procedures outlined in NASA's Self-Assessment Guide
and the directions included in the Associate Administrator for
Procurement memoranda of September 30, 1998 and February 18, 2000.

This report contains a summary of the findings and recommendations to
improve weaknesses. All actions surveyed were identified in the last
NASA HQ Procurement Management Survey Report as having weaknesses. This
report will be retained as a quality record under the ISO process, as
required.

# Methodology

This self-assessment focused on specific areas of weakness identified in
the most recent NASA HQ Procurement Management Survey Report which
occurred during the period of August 15 through August 26, 2005. In
addition, this self-assessment focused on corrective actions for
selected areas where weaknesses were identified. Reviews of a
representative sample of procurement actions that were identified as
having weaknesses in the NASA HQ Procurement Management Survey Report
were conducted for actions awarded or active during fiscal years 2005
and 2006. The review focused on requests for Supply and Equipment
Management Officer (SEMO) solicitation reviews, interagency purchase
order statements of work, prenegotiation position memoranda (PPM) and
Price Negotiation Memoranda (PNM), Fee Rationale (NF 634) analyses,
technical evaluations, subcontract consents, sole source simplified
acquisitions, COTR certifications and non-1102 contracting officer
warrants and Other Buying Authorities. In accordance with the guidance
provided in the NASA Self-Assessment Guide, we reviewed at least five
percent of each of these actions.

The report addresses those areas where inconsistencies or non
compliances were found. For the most part, all of the files were neatly
filed and maintained, and except as noted in this report, contained all
of the required, compliant documentation.

# Review Team

The following individuals participated as members of the self-assessment
review team, focusing on the areas specified:

  ------------------------------------------- ---------------------------
  **Name (Code)**                             **Functional Area
                                              Reviewed**

  Amanda Kreusch (210.H)                      SEMO Reviews

  Jennifer Perez (210.Y)                      Interagency Work Statements

  Klaus Sexton (210.M), Teresa Anthony        PPM/PNM documentation, Fee
  (210.S), Nylse Ortiz-Collazo (210.I)        Rationale, Technical
                                              Evaluations

  Monica Price (210.S)                        Subcontract Consent

  Russelyn Rogers (210.M)                     Sole Source Simplified
                                              Acquisitions

  Rex Elliott (210)                           COTR Certifications,
                                              non-1102 Warrants & Other
                                              Buying Authorities
  ------------------------------------------- ---------------------------

# Scope of Review

The SAP database was the primary system used to select the random sample
pool. Using the recommended review percentages as a minimum, the
following numbers of procurement actions were selected for this review:

+---------------------------------------+----------------+------------+
| **Type of**                           | **Total        | **Number** |
|                                       | Number**       |            |
| **Procurement**                       |                | **         |
|                                       | **Of Actions** | Reviewed** |
+---------------------------------------+----------------+------------+
| SEMO Reviews                          | 168            | 30         |
+---------------------------------------+----------------+------------+
| Interagency Work Statements           | 296            | 22         |
+---------------------------------------+----------------+------------+
| PPM/PNM Documentation                 | 233            | 23         |
+---------------------------------------+----------------+------------+
| Fee Rationale (NF 634)                | 121            | 18         |
+---------------------------------------+----------------+------------+
| Technical Evaluations                 | 203            | 18         |
+---------------------------------------+----------------+------------+
| Subcontract Consent                   | 487            | 25         |
+---------------------------------------+----------------+------------+
| Sole Source Simplified Acquisitions   | 275            | 16         |
+---------------------------------------+----------------+------------+
| Total                                 | 1783           | 152        |
+---------------------------------------+----------------+------------+

The actions selected reflected a sampling across all procurement offices
and specialists as well as a variety of contract types and actions with
small and large businesses, universities, nonprofits, other governmental
organizations, and foreign entities.

The NASA Procurement Self-Assessment Guide provides wide latitude and
flexibility in how Centers conduct their reviews and the specific areas
scrutinized. The last self-assessment examined the evaluation of past
contractor performance (NF 1680), cost plus award fee contracts,
interagency acquisitions, construction contracts, and architect and
engineering (A&E) contracts; and provided suggestions on how
deficiencies and problems noted could be improved. The scope of that
review resulted from weaknesses reported in the 2005 NASA HQ Procurement
Management Survey Report.

This April 2007 Self-Assessment concentrated on those remaining areas
that had previously been identified as having weaknesses in the last
NASA HQ Procurement Management Survey Report. Accordingly, it provides
recommendations for corrective actions and also includes comparisons
with the previous NASA HQ's Procurement Survey. A few of the items that
surfaced as problems or deficiencies in the prior NASA HQ's Procurement
Survey Report were again noted during this Self-Assessment. Possible
reasons for this as well as suggested solutions are contained in
Attachment A, "Overall Assessment and Recommendations".

# EVALUATION OF SEMO REVIEWS

# 

# 

The NASA FAR Supplement requires that \"The contracting officer shall
provide a copy of the solicitation (or contract if no solicitation is
used) to the center supply and equipment management officer (SEMO) for
review for acquisitions with an estimated cost greater than \$1,000,000,
or for acquisitions over \$50,000 when work is to be performed at the
center, existing Government property is being furnished, or contract
acquisition of Government property is required or permitted." (NFS
1845.102-71(b))

**[Findings: (*SEMO Reviews*]{.underline}):**

A total of 30 files meeting the above criteria were randomly selected
for review and were reviewed.  Of the 30, six contained no information
at all pertaining to the SEMO review, and four contained documentation
of the request that the SEMO review the file, but no documentation that
the solicitation was actually reviewed.  Twenty files were fully
compliant with the SEMO review requirement, showing both the request for
the SEMO\'s review and the actual response from the SEMO.

**[Recommendations (*SEMO Reviews*]{.underline}):**

While almost 70 percent of the sample showed full compliance with the
NASA FAR Supplement\'s requirements regarding SEMO reviews, we do not
believe this is sufficient. Almost 20 percent of the files showed no
attempt at compliance with this NFS regulation, and this is a problem
that should be addressed by re-emphasizing to Code 210 personnel the
existence of these requirements and their importance. We believe this is
particularly true for buyers, the group that, based on our sample
results, was most likely to not seek a SEMO review. The remaining 10
percent showed that the contract specialist/buyer was aware of the
requirement to obtain a SEMO review and had requested one, but that the
SEMO had apparently not responded or had not responded in a timely
manner, since there was no SEMO review in the file. We believe the SEMO
should be encouraged to provide timely responses to contract
specialists/buyers who request their reviews of solicitations/contracts.
In addition, we recommend revising the Code 210 Review and Approval
matrix so that it is clear that contract specialists/buyers must seek a
SEMO review of their contracts when no solicitation is available and
that the threshold for seeking a SEMO review for onsite performance is
\$50K.

# EVALUATION OF INTERAGENCY ACQUISITIONS

A total of 22 Interagency Acquisitions (IA's) were randomly selected for
review. The IA's reviewed were with a variety of Government agencies.

The statements of work were evaluated based on whether they contained a
description of the overall effort (scope), a description of the
deliverables, how thorough these descriptions were, pricing terms (for
the deliverable items) delivery/completion date(s), and whether they
contained a procedure for resolution of disagreements that may arise (as
recommended by FAR 17.504(C) and the 2005 GSFC Procurement Survey). Then
the files were given a rating of Very Good, Marginal or Poor.

In evaluating these IAs, we examined whether the following standard was
adhered to: *\"The Contracting Officer shall review the statement of
work and other documents to determine that the supplies or services
requested under the IA are within the scope of the servicing agency's
contract and confirm this determination with the servicing agency's
Contracting Officer. The Contracting Officer shall document this review
in the written Determination and Findings\".* This standard was taken
from a previous self-assessment.

  ---------------- ------------------ ------------------ ------------------
  Sample Size      Files with All     Files Missing Some Files Missing the
                   Required           Required           Statement of Work
                   Documentation      Documentation      

  22               4                  16                 9
  ---------------- ------------------ ------------------ ------------------

**[Findings (*Interagency Acquisitions*]{.underline}):**

Proposals and research announcements were found in all twenty-two IA
files. Twenty of the files had both a statement of work, and a proposal,
however two files did not have a statement of work at all, and received
a rating of Poor. Large and complex projects require that detailed work
requirements need to be written containing \"what is to be done\" in
definitive and precise language and terminology. The purpose of a SOW is
to detail the work requirements for projects and programs that have
deliverables and/or services performed. In eight of the files, the
purpose of the SOW was clear, but the deliverables, and delivery dates
were missing. Usually, this was true with SOWs for services, but we also
found this to be true on some SOWs for end-items.

In ten of the files, the D&Fs were less than adequate because they
contained such a brief description of the scope that it was impossible
to determine whether the IA was within the scope of the servicing
agency\'s contract.

Only four files received a rating of Very Good, these files clearly met
the evaluation requirements (scope, clear SOW description, completion
dates, and (where applicable) pricing terms, deliverables, and
deliverable due dates.)

Sixteen files received a rating of Marginal, which was based on a
generally well written statement of work, but were missing other
elements of the evaluation criteria such as a scope determination, D&F,
deliverables or pricing terms.

**[Recommendations *(Interagency Acquisitions*):]{.underline}**

Overall, our observations were that, although there have been
improvements in the general quality of the SOWs included in IAs, more
improvement is still necessary. In particular, we believe the technical
community still needs guidance on how to complete the SOWs that go into
IAs and that contract specialists and contracting officers need to
ensure that the SOWs that go into IAs are fully adequate. We recommend
targeting this finding to those Code 210 individuals who are most likely
to award IAs. We further recommend that a review tool (e.g. checklist)
be developed to make compliance with this requirement more routine (the
GSFC Procurement Circular 99-3 on this subject comes very close to
having a checklist, so it would not require much adaptation to meet this
suggestion).

# PRENEGOTIATION POSITION MEMORANDA/PRICE NEGOTIATION MEMORANDA DOCUMENTATION

# 

For this survey a random sample of contract files were drawn from all
active GSFC contract files. For this survey we obtained a sample of 23
contract files to include a) large competitive and non-competitive
acquisitions, b) small business set-aside competitive acquisitions, c)
8(a) set-aside acquisitions and d) non-profit acquisitions. We looked
for a) appropriate inclusion of file documentation, b) accuracy and
thoroughness of documentation, c) linkage of PPM to PNM, d) adequate
addressing of business system findings, and e) appropriate incorporation
of technical and pricing findings. It is noted that our random sample
included files where a PPM and PNM where either not applicable or
changes to the contract had not yet been made necessitating the
preparation of such documentation. The following summarizes the survey
sample.

  ------------ -------------- --------------- --------------- --------------
  Sample Size  Files with     Required        Adequate        N/A Files (no
               PPM, PNM or    Documentation   Justification   PPM/PNM
               Stand-Alone    in File         for Negotiated  Required)
               PNM                            Amounts         

  23           11             10              9               12
  ------------ -------------- --------------- --------------- --------------

It is noted that for this survey we did not make comparisons in quality,
only whether sufficient narrative information was included to
substantiate the finding of "fair and reasonable." The chart above does
not include IDIQ tasks in NASA's Task Order Management System (TOMS),
which is used on multiple, large contracts at GSFC. This is addressed
separately below.

**[Findings *(PPM/PNM Documentation)*:]{.underline}**

Our findings revealed that all but one contract file where a PPM, PNM or
stand-alone PNM was required contained the required documentation. In
the one instance, there was no PPM or PNM to support the negotiated and
executed contract modification. This file did include a request to
perform a stand-alone PNM, however, there was no evidence of approval.
In all other cases the PPMs and PNMs were well documented with an
adequate level of supporting detail. The negotiators appropriately
relied on recommendations from technical evaluations and audited pricing
data (i.e. they used this information but did not overly rely on it to
develop their rationale supporting the determination of fair and
reasonable pricing). In cases where the objective position was not
achieved, the PNM appropriately addressed the reasons for negotiating
otherwise. Stand-alone PNMs were appropriately utilized.

We did note that in some cases evaluation of subcontracted costs could
have been more detailed in the PPM. In one case, the negotiator
justified subcontract costs solely on the basis of the prime contractor
having an approved purchasing system. However, based on the survey
sample size, we would not characterize this finding to imply a systemic
problem. Also, on contracts utilizing TOMS, frequently there is no
detail contained in the ODC field to justify subcontracted costs as fair
and reasonable.

Further, the status of business system findings were often documented,
however, the impact this had on negotiations was not always addressed.

**[Recommendations *(PPM/PNM Documentation):*]{.underline}**

We recommend further vigilance to assure all files contain appropriate
documentation to justify negotiated contract actions. We recommend
additional emphasis on the analysis of subcontract costs. The prime
contractor should provide a basis for all estimates contained in its
proposals, but the contract specialist must determine the reasonableness
of the negotiated amounts. The impact of business system status on
negotiations should be more clearly addressed within the PPM. Within
TOMS, negotiators should document their finding in respect to ODCs.

# FEE RATIONALE (NF 634)

For this survey a random sample of contract files were drawn from all
active GSFC contract files. For this survey we obtained a sample of 18
contract files to include a) large business competitive and
non-competitive acquisitions, b) small business competitive and
non-competitive acquisitions, c) 8(a) set-aside acquisitions and d) a
foreign acquisition. We looked for a) appropriate inclusion of file
documentation, and b) accuracy and thoroughness. The following
summarizes the survey sample.

  ------------- ------------- --------------- ------------- ---------------------
  Sample Size   Files         Required        NF 634        NF 634
                requiring the Documentation   adequately    errors/inadequately
                use of NF 634 in File         documented    documented

  18            8             8               7             1
  ------------- ------------- --------------- ------------- ---------------------

**[Findings *(NF 634)*:]{.underline}**

Of the 8 contract files that included actions requiring the use of the
NF 634 Structured Fee Approach, all 8 contained the appropriate form. 7
of 8 forms were correctly filled in with no mathematical errors, and
included the associated narrative justification. The written narrative
justification for percentage weight selections included the appropriate
level of detail. In only one case did we find mathematical errors on the
form. This same form also included an inadequate narrative justification
for the weight selections.

**[Recommendations *(NF 634):*]{.underline}**

We recommend Code 210 Contracting Officers continue to closely examine
the NF 634 to eliminate mathematical errors and assure sufficient
narrative justification for the percentage weight selections.

# TECHNICAL EVALUATIONS

For this survey a random sample of contract files were drawn from all
active GSFC contract files. For this survey we obtained a sample of 18
contract files to include a) large business competitive and
non-competitive acquisitions, b) small business competitive
acquisitions, c) 8(a) set-aside acquisitions and d) non-profit
acquisitions. We looked for a) the request for technical evaluation, b)
the content of the request for technical evaluation, and c) inclusion of
the content of the technical evaluation. It is noted that our random
sample included files where a technical evaluation was either not
applicable or changes to the contract had not yet been made
necessitating the preparation of such documentation. The following
summarizes the survey sample.

  ------------ ------------------------- ---------------- ----------------
  Sample Size  Files with contract       Files with a     N/A Files---No
               actions requiring a       Request for      technical
               technical evaluation      technical        evaluation
                                         evaluation       required

  18           8                         4                10
  ------------ ------------------------- ---------------- ----------------

**[Findings *(Technical Evaluations)*:]{.underline}**

All 8 of the files that required a technical evaluation included one.
Six of the 8 technical evaluations were deemed to be excellent and
adequately addressed all elements. Of the other two, one technical
evaluation relied heavily on financial data rather than "types and
quantities". This technical evaluation contained no discussion of
materials, travel or subcontracted efforts. Approximately \$260K of
subcontracted efforts appeared to have no technical rationale for
acceptance. Another technical evaluation provided little explanation to
why the estimates were deemed acceptable. Large subcontracts were
accepted with no technical substantiation and ODCs were addressed with
little detail to support the technical need.

Although there were eight technical evaluations, we found only four
requests for these. Three were deemed to adequately provide direction
regarding the required content of the technical evaluation, but excluded
a deadline. The other was an email request, but contained no detail to
the required content.

**[Recommendations (*Technical Evaluations*):]{.underline}**

We recommend contract specialists provide technical evaluators detailed
written requests for technical evaluations and such requests contain
specific direction in respect to the required content. We also recommend
the contract specialists ask for a technical evaluation addendum when
initial submissions inadequately address the technical need for "types
and quantities". We further recommend that Code 210 develop compile
sample (or template) technical evaluation requests for Code 210
personnel to use.

# SUBCONTRACT CONSENTS

Although we reviewed 25 files for subcontract consent, we found only one
subcontract consent in our sample. We believe this is because we did not
adequately structure the sample to include only those contracts for
which it was likely there would be subcontract consents. The one file we
reviewed contained subcontract consent that was fully adequate. The
consent letter adequately provided consent to the contractor\'s
placement of a subcontract without agreeing to the allowability of the
subcontract amounts. In addition, the file used a subcontract consent
checklist form from the prime contractor to help ensure the request was
complete.

Although the one file we reviewed was fully adequate, we cannot draw any
conclusions from this because the sample size was so small.

We recommend that GSFC attempt to assess this area in a future
self-assessment and that it try to ensure the sample contains a
sufficient number of subcontract consents to make it statistically
valid. We further recommend that future self-assessments assess the
degree to which the contracting officer adequately documents subcontract
consents with award of the basic contract (by including the specific
subcontractor in the subcontracts clause of the contract schedule).

# SOLE SOURCE SIMPLIFIED ACQUISITIONS

Although we requested a sample of 50 files (out of SAP records showing
275 sole source purchase orders above \$25,000 issued in the past two
years) we were able to retrieve only 16 files. This was a disappointing
sample size and is probably attributable to several conditions. Although
we removed from our sample any files that showed accession numbers
(indicating the PO was in the process of being closed out) there were
probably some additional POs in closeout where the SAP records did not
show an accession number. In addition, we noticed an abnormally large
number of the requested files had incorrect buyers assigned to them.
Some of this is clearly due to changing buyer assignments (yet not
updating the SAP records to reflect this). However, we believe some of
this is also due to the transition confusion associated with
implementation of the Contract Management Module (CMM). Whatever the
cause(s), we recognize that this sample size is small and thus our
findings will be of questionable applicability to the larger population.

## **[Findings *(Sole Source Simplified Acquisitions) *]{.underline}**

Of the sixteen files we reviewed, 10 contained adequate sole source
justifications in the file, 2 did not require any justification (since
they were for NISH vendors who are authorized for sole source selection
by part 8 of the FAR) and 2 were completely missing the required sole
source justification. Another PO contained an adequate sole source
justification, but it was not signed by a contracting officer. The
remaining PO was actually conducted as a competitive acquisition that
received only one acceptable offer, and thus was incorrectly coded in
SAP as a sole source PO. In addition, one of the files that contained an
acceptable sole source justification used an outdated "Justification for
Non-Competitive Procurement" instead of the required "Justification for
Sole Source", but the rationale contained in the document was
nonetheless an acceptable justification.

We also reviewed these sixteen files for the adequacy of the cost/price
analysis. Most of the files used a form to indicate the rationale behind
the determination of price reasonableness. We found 5 files that
contained fully adequate price analysis and documentation. We also found
8 files that had checked a form, indicating that the price was deemed to
be reasonable based upon one of several factors listed on the form (i.e.
the analysis was done by reference). However, since we found no other
documentation supporting the price reasonableness determination, and the
applicability of the checklist was not self-evident, we deemed this to
be only partially compliant with the requirement for a price
reasonableness determination. The remaining 2 files did not contain any
price analysis at all.

## **[Recommendations *(Sole Source Simplified Acquisitions) *]{.underline}**

We recommend that purchasing agents be regularly acquainted with the
requirement for documenting their files with adequate sole source
justifications and adequate price reasonableness determinations. We
further recommend that the forms used by purchasing agents to document
price reasonableness determinations be reviewed so that 1) they are
standardized, and 2) they call for the purchasing agent to fill-in
whatever additional documentation or analysis is required to meet the
FAR standard of reasonableness (i.e. would a prudent business person in
a competitive environment agree to this, and why).

Regarding the problems with obtaining a representative sample, we
believe that some of this problem will go away as CMM gets fully
instituted at GSFC. Some SAP records were not converted to CMM, but the
pool of these will diminish over time. In addition, we recognize that
the problem of "outdated ownership" of SAP records may well grow worse
because of CMM's requirement that a contract modification be used to
update the ownership of an SAP file. Writing, signing, and entering
these modifications into SAP will take time, and this time lag
effectively reduces the accuracy of SAP data. Nonetheless, we also
believe that all Code 210 personnel should be encouraged to regularly
update their SAP files as quickly as possible so that the ownership and
accessibility are maintained as accurately as the functional limitations
and other shortcomings of SAP will allow.

# CONTRACTING OFFICER TECHNICAL REPRESENTATIVES

GSFC maintains a database of Contracting Officer Technical
Representatives (COTRs). Before delegating authority to be a COTR, the
contracting officer is supposed to ensure the person is listed on the
database of currently certified COTRs. A person is put on the database
after completing the COTR Certification course. In addition, to stay on
the database, the person is supposed to complete the COTR Refresher
course at least once every 5 years.

As of March 30, 2007 there were 926 COTRS listed on the GSFC database
and 300 listed on the database for NASA Headquarters. The NASA Office of
the Inspector General recently completed a review of this database and
found that 17 percent of the persons in the HQ database had not taken
COTR training in the last 5 years. All persons in the GSFC database had
taken COTR training within the last five years. In addition, we saw that
GSFC is currently in the process of developing GSFC-specific COTR
Certification and COTR Refresher courses that are just about to be
rolled-out.

## 

## **[Findings *(COTRS ) *]{.underline}**

The new GSFC-specific COTR Certification and COTR Refresher courses are
tailored to address the specific procurement policies and situations
that arise at GSFC. Nonetheless, we found that the availability of this
course is generally not well known. We believe this resource could be
better utilized, both by the technical community and by resources and
procurement personnel.

## **[Recommendations *(COTRS) *]{.underline}**

We recommend that the procurement organization give greater attention to
publicizing the availability of the new GSFC-tailored COTR courses, and
that more technical and procurement personnel be encouraged to attend.
We further recommend that GSFC consider issuing procurement circular or
work instruction to have contracting officers/contract specialists
ensure that a person is currently certified to be a COTR before they are
delegated authority to be a COTR. Since the HQ COTR database includes a
number of unqualified COTRs, we recommend that these individuals be
reminded of the requirement to take COTR certification or refresher
training, and that those with outdated credentials be purged from the
database. We further recommend that a concerted effort be made to
publicize the availability of HQ COTR training so that individuals are
reminded of their opportunities to receive required training. We noted
the response to a recent Office of Inspector General report that: \"*It
should not be the Director of GSFC but an appropriate technical
individual at HQ who is responsible for ensuring the active HQ COTRs
take the required training\",* and we believe this should be
considered*.* We further believe the advent of NASA\'s new instructional
learning system (SATERN) has likely caused some confusion in terms of
which courses are available. This is not a criticism of SATERN, since we
believe this confusion would occur with the implementation of any new
system.

# NON-1102 WARRANTS AND OTHER BUYING AUTHORITIES

In January 2006, Code 210 adopted a policy (available at:
<http://code210.gsfc.nasa.gov/>) for the appointment and training of
contracting officers and other buying authorities outside of the GSFC
procurement organization. This policy describes the criteria for
appointment, required training, limitations, and process for obtaining
these authorities. We reviewed the policy and discussed its efficacy
with the division\'s procurement training coordinator. We further
reviewed the files associated with these policies.

## **[Findings *(Non-1102 Warrants and Other Buying Authorities) *]{.underline}**

Since adoption of this policy, the GSFC Procurement Officer has formally
approved 12 personnel for the Other Buying Authority---the authority to
issue orders against Blanket Purchase Agreements (BPAs) that the
procurement organization has awarded. The files show that each of these
personnel has completed the required training and prepared the
appropriate request for this authority. In addition, we found that Code
210\'s database of contracting officers includes the personnel who are
outside of the procurement organization (the non-1102 personnel who have
contracting officer warrants), and the files of contracting officer
warrants include these personnel as well. It is noted that the new
policy applies to all non-1102 recipients of contracting officer
warrants, even though none have been issued since formalization of the
policy.

The policy appears to be functioning relatively well, although it has
some minor discrepancies. The policy does not make mention of the
limitations on BPA ordering authority in NFS 1813.303-3, even though
BPAs are the only \"other buying authority\" that has been issued so
far. In addition, it\'s not clear to what extent other BPAs (outside of
the 12 individuals authorized so far) are being used at GSFC and HQ.

## **[Recommendations *(Non-1102 Warrants and Other Buying Authorities) *]{.underline}**

We recommend that the procurement organization review its policy for
issuing warrants to non-1102 personnel and for other buying authorities
to ensure that the way it is being implemented is not in conflict with
the FAR or NASA FAR Supplement. We further recommend that contracting
officers/contract specialists be reminded of the NFS restrictions
concerning the issuing of task/delivery orders on IDIQ contracts or
orders against a BPA. We further recommend that the division analyze
what other BPAs (and other buying authorities) are at GSFC and HQ that
should be included under the new policy.

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# ATTACHMENT TO THE SELF-ASSESSMENT REPORT 

# Attachment A\--Overall Assessment And Recommendations

Overall, the Self-Assessment Team found the procurement files reviewed
to be generally complete, well organized, and well documented. The chief
concern is that a few of the findings noted in the last NASA HQ
Procurement Management Survey Report have [not]{.underline} been
corrected. This may be indicative of a systemic problem in certain
procurement areas (such as communication and implementation of policy,
guidance, and regulatory changes, and/or inadequate or insufficient
training) or it could be the result of the high turnover in personnel
experienced in the last few years. Additionally, the repeat weaknesses
that were identified were in the area of contract administration. It
would appear that more emphasis and time should be allotted for the
performance of contract administration functions which often seem to
take less of a priority than new award functions. Inconsistencies and
oversights noted in the files may also be attributed to heavy workloads,
as well as a workforce with a number of relatively inexperienced
personnel in terms of being new to procurement or new to Goddard (with
experience coming from another Government agency). Regardless of the
reasons, these findings need to be addressed globally within the
procurement community in an effort to eliminate some of the more
critical and obvious problems so that they will not reappear in future
audits and assessments. By doing this we should also improve the overall
quality of our procurement process and products.

A multi-pronged approach is suggested to tackle this problem, as
detailed below.

-   The comments and recommendations in this report should be
    communicated to Division Management (PODBOD, Senior Staff, and
    Procurement Managers) by means of e-mail (with follow-up or further
    discussion in a future Topic Staff meeting, if necessary). The
    comments and recommendations should then be conveyed to each
    procurement office through face-to-face meetings or other forums
    where contracting personnel can learn and discuss weak areas of
    contract administration. Meeting in small groups such as this should
    facilitate discussion and make presentation of the information more
    personal for each of the employees. They will be meeting within
    their own work groups and may be more comfortable about discussing
    these issues and asking questions. Findings from both the
    Self-Assessment and the HQs Survey Report should be discussed since
    there are many duplicate areas of concern. This will also be an
    opportunity to provide the background of each report---purpose,
    intent, importance and timing of the Self-Assessments and NASA HQ's
    Survey Team review. One best practice being utilized successfully
    has been that of an Associate, who sends weekly Monday morning
    emails to all employees of her offices that include personnel news,
    kudos received from customers, reminders of upcoming actions, as
    well as areas of contract administration that need more attention,
    based on recent reviews of files as well as survey and audit
    findings.

-   Written guidance, as needed, should be disseminated to the
    procurement community.

-   An assessment of training needs and appropriate forums for this will
    be discussed with the Senior Staff member overseeing Human Capital
    Development.

-   As a division, and as a procurement culture, more

-   emphasis should be placed on the importance of contract
    administration functions. Contract administration functions and
    contract award function should be of equal significance. At present
    there is a disparity between the \"front- end\" procurement process
    and the \"back-end\" procurement process and the time devoted to
    these functions. Contract specialists at GSFC are responsible for
    both.

-   Finally, it is important to provide a closed loop process so that
    new knowledge and lessons learned as a result of this and future
    Self-Assessments and the HQ's Surveys are fed back into guiding
    documents, local policy, and training forums. Equally important is
    devising a way to measure success in this arena. Certainly one
    metric will be the results of the next NASA HQ's Survey and a future
    Self-Assessment Review. The primary areas of concern noted in this
    report should be targeted in future self-assessment reviews to
    assess if corrective actions taken have resulted in improvement.

-   

-   

-   **[Summary]{.underline}**

The procurement workforce is dynamic and industrious. The number of
actions of varying complexity and dollar value processed in any given
time period can be overwhelming. It is sometimes difficult to maintain a
balance between quality and timeliness so the procurement workforce
often unwittingly compromises work quality to meet the mission needs and
requirements of our technical customers. It is important, however, to
take the requisite time to periodically stand back and objectively
examine the work products to ensure that quality is not unduly
compromised or eroded. Accordingly, with the goal of improving the
quality of the procurement work products and increasing the knowledge
and understanding of the procurement function, it is hoped that the
variety of communication methods detailed above will obtain the desired
results.