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> **DEPARTMENT OF HEALTH & HUMAN SERVICES** Public Health Service
>
> National Institutes of Health Bethesda, Maryland 20892
>
> [www.nih.gov](http://www.nih.gov/)

Date: May 8, 2008 **(Revised May 16, 2008)**

To: NIH Acquisition Community

From: Head of Contracting Activity

> and Director, Office of Acquisition and Logistics Management, OM, NIH

Subject: Accomplishing the NIH DCIS Verification and Validation Plan

A March 9, 2007 memorandum from the Administrator, Office of Federal
Procurement Policy (OFPP) requires each Executive agency to:

-   Establish agency-wide requirement for statistically valid
    verification and validation of data submitted to FPDS-NG

-   Provide annual certification of data accuracy and completeness to
    the General Services Administration (GSA) (Initial annual statement
    of data verification and validation was provided to OFPP 12/15/2007)

-   Assign clear responsibilities for data verification

-   Modify policies, procedures, and training as necessary to ensure
    quality data quality

This OFPP requirement works in combination with the Federal Funding
Accountability and Transparency Act (FFATA) requirements for full
disclosure of all federal award information. Obviously, full disclosure
carries with it the expectation that the data is complete and accurate.

A review of a statistical sample of all OPDIVs' FPDS-NG data (entered by
NIH through DCIS) was done by LMI on behalf of DHHS in August and
October of 2007. The review resulted in findings of weaknesses in the
data completeness and accuracy. As a next step, all OPDIVs had to submit
to the Department a plan for verifying and validating its data in FY 08.
Action items from that plan are stated below.

-   The goal of this plan is to make significant improvements in data
    entry and data accuracy, as well as to learn from our approach in
    order to make future improvements. The goal for data entry is to
    have all data entered into DCIS by October 15, 2008. The goal for
    data accuracy is to understand better what is the correct data entry
    for each DCIS field and to reduce the number of errors made in data
    entry.

-   This year our focus is on the Top 10 FPDS-NG errors, the Top 10
    FPDS-NG "Critical Field" errors, and the Top 10 FPDS-NG FFATA Field
    errors, as identified by LMI in its review. Attachment A, DCIS Data
    Entry Errors; Instructional Information, presents definitions for
    the fields, information on the nature of the errors and their
    probable cause(s), types of actions where an entry is required,
    whether the field is populated by PRISM, and a suggested solution to
    the error.

-   As part of the monitoring of the effort to improve data entry, the
    Contracts Data Management Program (CDMP) in the Office of
    Acquisition and Logistics Management will be running DCIS reports to
    see what award data has been entered and which entries are
    unfinished. They also will be running nVision reports to compare
    with the DCIS reports so that awards in NBS that have not been
    entered into DCIS can be identified. This will allow us to notify
    the NBS Buyer and their supervisor that the DCIS data entry has not
    been done.

-   CDMP also is working with DHHS/DCIS and the DCIS Configuration
    Control Board to bring about edits, changes, and improved
    descriptions of fields as needed. It is important to note that a new
    version of FPDS will be implemented by DHHS effective October 1.
    Entry of data prior to that time will use existing, known rules and
    edits.

-   Training the trainers also will be done as part of the NIH DCIS
    Verification and Validation Plan for FY 2008. Each of the ten
    Offices of Acquisition will be briefed on this plan. The Division of
    Simplified Acquisition Policy and Services will arrange train the
    trainer sessions for key delegated acquisition staff in the ICs.
    This probably will be done on a geographical basis, e.g., NIH
    campus-Intramural, NIH campus-Extramural, Rockledge I and II,
    Executive Boulevard, Democracy II, with multiple IC attendees at
    each site.

-   Directors of Offices of Acquisition and Lead Intramural and
    Extramural AOs for each IC will be sent a certification to be signed
    attesting that the training and dissemination of the information on
    the NIH FY 08 plan has been provided to all Buyers in their
    organizations.

-   As is done currently, data from new awards and modifications of new
    awards begun in NBS will be entered through PRISM. Data from
    converted awards still will need to be entered directly into DCIS
    rather than through PRISM.

-   A print out of DCIS data entry must be placed in the award file for
    CO/Award Approver review. Review prior to award on 100% of actions
    is our goal; however, at a minimum each Contract Specialist/Buyer
    must have at least one action, including DCIS data entry, reviewed
    per quarter.

-   The Division of Acquisition Policy and Evaluation and the Division
    of Simplified Acquisition Policy and Services also will continue to
    do Board of Contract Award Reviews and other file reviews.

-   Finally, though not officially part of the NIH Plan, a clear,
    official decision is needed on entry of data on task and delivery
    orders and BPA calls. NIH does not get credit for many of these
    awards because the data is not entered. Consequently, when we are
    judged on the amount of work we do with the staff we have, we appear
    to be doing less with those staff than is true.

> To correct this, the requirements stated below for DCIS data entry,
> which have been understood by some but not by all, are mandatory.
> These requirements apply to all NIH-wide IDIQ contracts, NITAAC
> contracts, and BPAs, whether used by those role mapped as Buyers in
> Offices of Acquisition or those role mapped as Buyers in the delegated
> community. If you use NBS/PRISM to place an order or call, or ADB to
> modify an existing order or call, this applies to you.

1.  The basic rule is that the person (office) who places the
    task/delivery order or BPA call in PRISM is the person (office) who
    enters the data into DCIS. The person (office) who awarded the
    "parent" contract or BPA enters only that "parent" into DCIS. They
    do [not]{.underline} enter orders or call placed by others.

2.  Complete, accurate data entry must be done. If training is needed to
    accomplish this, contact the CDMP team to arrange the training.

> OALM, in particular its CDMP team, will be the central point of
> contact for collection of ongoing issues, receipt of additional
> information related to DCIS Verification and Validation, and insuring
> that staff are notified of and, as necessary, trained on continuing
> problems and new issues. Ms. Paulette Smith, 301-496-1783, is the team
> lead for CDMP. CDMP will work with the Directors, Offices of
> Acquisition, Lead Administrative Officers, and the Division of
> Simplified Acquisition Policy and Services to accomplish the
> activities set forth in this memo.

Diane J. Frasier

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