SBA'S EFFORTS TO IMPROVE THE QUALITY 


OF ACQUISITION DATA IN THE FEDERAL 


PROCUREMENT DATA SYSTEM 


Report Number: 10-08 


Date Issued: February 26,2010 

Office 

u.s. Small 

of Inspector 

Business 

General 

Administration Memorandum

To: 	 Darryl K. Hairston Date: February 26,2010 

Associate Administrator 

Office of Management and Administration 

lsi Original Signed 

From: 	 Debra S. Ritt 
 

Assistant Inspector General for Auditing 
 

Subject: 	 Audit of the SBA's Efforts to Improve the Quality of Acquisition Data in the Federal 

Procurement Data System, Report No. 10-08 

This report presents the results of our audit of the quality of SBA' s acquisition 

data in the Federal Procurement Data System (FPDS). Based on data quality 

concerns raised by the Government Accountability Office (GAO), in 2007 the 

Office of Management and Budget (OMB) issued a directive requiring Federal 

agencies to annually certify to the accuracy of procurement data reported in FPDS. 

Data in FPDS must be accurate because it is used to report on Government 

contracting actions, procurement trends, achievement of small business goals, and 

to report contract activity under the American Reinvestment and Recovery Act 

(Recovery Act). In 2008, OMB also required that agencies annually implement 

data quality plans. Beginning in fiscal year (FY) 2005, OMB required Federal 

agencies to convert to a contract writing system that directly interfaces with 

FPDS. 1 SBA met this requirement in 2009 when it converted from Comprizon to 

PRIZM. 

The objectives of the audit were to determine whether SBA had (1) taken adequate 

steps to ensure the accuracy of its FY 2008 acquisition data, and (2) developed a 

data quality plan to effectively address any data weaknesses. Additionally, at 

management's request, we determined whether the quality ofFPDS data improved 

with the conversion to a new contract writing system in FY 2009. To achieve the 

audit objectives, we examined SBA's process for ensuring the accuracy of its 

acquisition data; reviewed relevant policies, procedures, and regulations; reviewed 

a copy of SBA' s FY 2008 FPDS Data Quality Plan and SBA' s FY 2008 

certification to OMB; and interviewed personnel in SBA's Office of Business 

Operations (OBO). We also analyzed a random sample of SBA's contract 

10MB Memorandum, Timely and Accurate Procurement Data, August 25, 2004. 
2 

actions - 36 in FY 2008 and 35 in FY 2009 2 to determine whether the data in 

FPDS matched information contained in SBA's contract files. In assessing data 

accuracy, we focused our review on 18 of the 46 key data elements identified by 

OMB, that were either legislatively mandated3 or which described the nature of 

the contract action. The data elements selected for review and our sampling 

methodology are contained in Appendix I. We conducted our audit between May 

2009 and December 2009 in accordance with Government Auditing Standards 

prescribed by the Comptroller General of the United States. 

We found that SBA certified to the accuracy of its FY 2008 contracting data, 

although 92 percent of the contract actions in our sample contained one or more 

inaccurate or incomplete data elements in FPDS. While SBA had developed a 

data quality plan for FY 2008, it did not fully implement the plan, which 

contributed to the errors identified. Further, due to the volume of errors identified 

in FPDS, it appears that contracting personnel did not review FPDS data inputs to 

ensure they reflected accurate information, as required by the Federal Acquisition 

Regulations (FAR). Finally, while the accuracy of some data elements improved 

in FY 2009, overall there was a higher rate of error in the FY 2009 data. 

Approximately 97 percent of the contract actions in our sample contained one or 

more inaccurate or incomplete data elements, indicating again that SBA 

contracting personnel were not properly reviewing data entries. 

We recommended that the Associate Administrator for Management and 

Administration identify steps that will be taken to ensure that contracting data is 

reviewed for accuracy and completeness, conduct an independent review to 

determine whether the Data Quality Plan has been fully implemented, and hold 

OBO personnel accountable for the accuracy of FPDS data. Management 

concurred with the report findings and recommendations and agreed to take 

appropriate action. 

BACKGROUND 

FAR requires Federal agencies to enter information on all of their reportable 

contract actions 4 into FPDS 5 and to certify annually to its accuracy.6 Congress, 

Federal agencies, and the public rely on FPDS for a broad range of data on 

contracting actions and spending. This information is also used to assess the 

2 The sample included contract actions that occurred between October 2008 and March 2009. 
 

3 Public Law 109-282, Federal Funding and Transparency Act 0/2006, September 26, 2006. 
 

4 Reportable Contract Actions are defIned by FAR Part 4.601 as any action that results in the purchase, rent, or lease of 
 

supplies or equipment, services or construction using appropriated dollars over the micro purchase threshold; or 

modifIcations to these actions regardless ofvalue. 

5 FAR Part 4.602(a). 

6 FAR Part 4.604(c). 
3 

extent to which Federal agencies are meeting their small business goals and to 

report to Recovery.gov on contracting activity financed by the Recovery Act. 

In September 2005, the GAO reported a lack of confidence in the ability of FPDS 

to provide timely and accurate data and recommended that agencies verify the 

accuracy and completeness of their data in FPDS. 7 Based on concerns raised by 

GAO and the need to ensure the public has accurate data on Federal procurements, 

beginning in 2007, OMB directed procuring agencies to take steps to improve the 

quality of data reported to FPDS. 8 Additionally in FY 2008, OMB required 

Federal agencies to submit Data Quality Plans, including actions that would be 

taken to validate contract actions entered into FPDS. In complying with this 

requirement, agencies were to determine the accuracy rates of 46 key data 

elements prescribed by OMB based on either a review of a statistical sample of 

contract actions or an alternative methodology. The FY 2008 Data Quality Plan 

was due to OMB by July 15,2008. Finally, by January 5, 2009, all agencies were 

required to certify that all reportable contract actions awarded during FY 2008 

were entered into FPDS as fully and accurately as possible. 

OBO is responsible for ensuring and certifying the accuracy and completeness of 

all SBA procurement information contained in FPDS. During FY 2008, SBA used 

Comprizon as its primary contract writing system, which did not have a direct 

interface with FPDS. Therefore, SBA manually entered the FY 2008 contract 

actions into FPDS. In FY 2009, the Agency converted to PRISM, which allowed 

contracting personnel to electronically transmit to FPDS procurement data for 

select fields. OBO contracting personnel manually enters information for all other 

fields. 

SBA certified that all 855 contract actions for FY 2008, valued at $72 million, 

were entered into FPDS as fully and accurately as possible. At the time of our 

audit fieldwork, the Agency had not certified to the accuracy of its FY 2009 data. 

Since issuance of the draft report, SBA certified on January 5, 2010, that 

99 percent of all contract actions for FY 2009, valued at $99 million, was entered 

into FPDS as fully and accurately as possible. 

7 GAO-05-960R, Improvements Needed to the FPDS-Next Generation, September 27, 2005 . 

80MB Memoranda, Federal Procurement Data Verification and Validation, March 9, 2007, and Improving 

Acquisition Data Quality-FY 2008 FPDS Data, May 9, 2008. 
4 

RESULTS 

SBA Did Not Take Sufficient Action to Ensure the Accuracy of its FY 2008 

FPDS Data 

SBA's process for ensuring the accuracy ofFY 2008 FPDS data was not adequate. 

According to OBO contracting personnel, after contract data was entered into 

FPDS, they printed a copy of the FPDS information and compared it to 

information in the contract file. If any discrepancies were identified between the 

two sets of information, corrections should have been made before finalizing the 

data in FPDS. While contract files contained a copy of the FPDS printout, our 

review of 36 sampled contract actions reported in FPDS disclosed that 33, or 

92 percent, contained one or more inaccurate entries 9 and/or were missing data 

elements. Of the 33 contract actions that had problems, 32 involved inaccurate 

data, and 11 had incomplete data elements. Some of the more prevalent data 

errors included: 

• 	 13 contract actions that had incorrect Data Universal Numbering System 

(DUNS) numbers-the contractor's unique identifier used for data 

retrieval. This type of error could result in an over- or understatement of 

contractor activity. 

• 	 11 that incorrectly reported the size of the business, the majority of which 

consisted of businesses being reported in FPDS as small, but the contract 

file reflected that they were other than small. The accuracy of this data 

element is important for SBA to properly receive credit for meeting their 

small business goals. 

• 	 6 that did not have North American Industrial Classification System 

(NAICS) codes that matched those in the contract files. The NAICS code 

is important because it provides the standard for determining whether a 

business is small, and eligible to receive small business contracts in a given 

industry. 

• 	 11 contract actions did not contain an accurate award type, which restricts 

the data fields for data entry. For example, because a Delivery Order was 

incorrectly entered as a Purchase Order, pertinent data fields for the 

Delivery Order were not accessible in the drop-down menu. This type of 

9 For the purposes of our report, inaccurate means the FPDS report and the contract file for the contract action did not 

contain matching information or the information was missing from the contract file for 156 of the 648 data elements 

reviewed. 
5 

error also skews the procurement statistics for the Agency and the Federal 

government that is reported in USAspending.gov. 

• 	 18 did not contain correct zip codes for the place of contract performance, 

causing some contracts to be reported as performed in the wrong 

Congressional district. 

Additionally, 11 contract actions (10 of which also had accuracy issues), had at 

least 1 data element that was blank in FPDS, even though it was a required 

element for the contract action based on the award type. For example, incomplete 

fields included the type of contract, description of requirements, and principal 

NAICS code, among others. 

Based on our sample results, we estimate that at least 681 of the 850 contract 

actions reported in FY 2008 had inaccurate or incomplete information. Our 

statistical projections are detailed in Appendix I, and a further description of the 

data errors by element is provided in Appendix II. 

SBA Did Not Fully Implement Its Data Quality Plan 

In preparation for its FY 2008 certification, the Agency established and submitted 

a Data Quality Plan to OMB that detailed steps to ensure the accuracy and 

completeness of information being reported in FPDS. Specifically, the Plan called 

for: 

• 	 Verifying and validating FPDS information to ensure the data entered was 

accurate and complete before awarding the contract. 

• 	 Verifying that contract obligations matched the information entered into 

FPDS. 

• 	 Verifying and validating FPDS data through a monthly statistical sampling 

of data entries. 

• 	 Reviewing obligations to ensure that all contract actions were entered into 

FPDS. 

• 	 Conducting an independent review, consisting of a statistically valid 


comparison of FPDS data and contract files. 


Although the plan included steps to review and verify the completeness and 

accuracy of FPDS data, the Agency only compared contract actions in Comprizon 

to those in FPDS to identify and complete those that had not been entered into 
6 

FPDS. While these reviews ensured that all contract actions were entered into 

FPDS, the Agency did not conduct additional tests as specified in the Plan, to 

ensure the data entered was accurate. The large volume of errors noted in our 

review would seem to indicate that contracting personnel were not reviewing 

FPDS inputs to ensure they accurately reflected contract actions. This occurred 

because contracting personnel were not held accountable for ensuring the accuracy 

of FPDS data. More importantly, the Agency did not conduct an independent 

review of a statistical sample of contract actions to validate the accuracy of FPDS 

data. 

According to OBO management, workload demands and a lack of resources 

hindered its ability to fully implement the Data Quality Plan. By not fully 

implementing the plan, the Agency inappropriately certified that its 855 contract 

actions were accurate. 

The Percentage of Contract Actions with Data Quality Issues Increased in 

FY 2009 with the Conversion to a New Contract Writing System 

Our review of 35 statistically sampled contract actions for FY 2009 determined 

that 34, or 97 percent, of the actions contained inaccurate 10 and/or incomplete 

data. 

Of the 34 actions, 30 contained 1 or more data elements that did not match data in 

contract files, and 12 were incomplete. Although more contract actions had data 

quality issues in FY 2009 than in FY 2008, the Agency's data entry improved for 

four of the five data elements discussed previously. For example: 

• 	 8 had incorrect DUNS numbers, compared to 13 observed for FY 2008. 

• 	 8 incorrectly reported the size of the business, compared to 11 that were 

identified for FY 2008. 

• 	 8 did not have NAICS codes that corresponded to that reported in the 
 

contract files, compared to the 6 observed for FY 2008. 
 

• 	 10 did not have matching award types, compared to 11 that were observed 

for FY 2008. 

• 	 15 did not contain correct zip codes for the place of contract performance, 

compared to 18 that were observed for FY 2008. 

10 The FPDS report and the contract file for the contract action did not contain matching information or the information 

was missing from the contract file for 141 of the 630 data elements reviewed. 
7 

Further, similar to what we observed with the FY 2008 data, 12 of the FY 2009 

contract actions contained one or more data elements that were blank in FPDS. 

The NAICS code was the data element that was most frequently left blank. Based 

on our analysis of the sampled contract actions, we estimate that at least 266 of the 

303 contract actions entered into FPDS by the SBA contained at least 1 error for 

the 18 data elements we reviewed. Complete results of our contract action 

analysis are detailed in Appendix I. 

These results indicate that SBA' s contracting personnel continue to insufficiently 

review the data entered into FPDS to ensure the data is correct and that all 

required fields are completed. Since SBA contract actions in FPDS contain 

information not matching the data in the contract files, inaccurate information is 

being made available to Congress and the public on SBA contracting activities, 

including potential Recovery Act actions. Also, SBA's Goaling Report may 

contain inaccurate information concerning the extent to which the Agency met its 

small business goals. 

In October 2009, OMB issued new guidance 11 on improving FPDS data quality for 

FY s 2009 and 2010 and eliminated the previous requirement to submit separate 

data quality plans and certification reports. The new guidance requires agencies to 

submit a single, annual Data Quality Report that includes the agency's 

certification of the completeness and accuracy of its FPDS data for the previous 

fiscal years, a description of activities to assure data input accuracy, and a 

summary of its policies and procedures for measuring and reporting data accuracy. 

Shortly after OMB issued its guidance, SBA issued an information notice 12 

regarding the certification of FPDS data and provided guidance to SBA 

contracting personnel on ensuring data quality. However, this notice does not 

contain sufficient detail regarding the steps that will be taken to ensure data is 

reviewed for accuracy and completeness. This level of detail will be needed to 

meet OMB's new guidance for improving and validating the accuracy ofFPDS 

data. 

110MB Memorandum, Improving Acquisition Data Quality for Fiscal Years 2009 and 2010, October 7, 2009. 

12 	 SBA Information Notice, Ensuring Accurate Procurement Data Reporting to the FPDS - Next Generation and 

Federal Assistance Award Database, October 19, 2009. 
8 

RECOMMENDATIONS 

We recommend that the Associate Administrator for Management and 

Administration to: 

1. 	 Either update the FY 2008 Data Quality Plan or revise the information notice 

to include explicit steps that will be taken to ensure data is reviewed for 

accuracy and completeness. 

2. 	 Conduct an independent review to ensure that the Data Quality Plan or 

information notice requirements have been fully implemented. 

3. 	 Ensure that OBO contracting personnel are held accountable for the accuracy 

of FPDS data. 

AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 

RESPONSE 

On January 7,2010, we provided a draft of the report to SBA's Office of 

Management and Administration for comment. On February 18, 2010, the 

Associate Administrator for Management and Administration provided written 

comments, which are contained in their entirety in Appendix III. Management 

agreed with our findings and concurred with all three recommendations. The 

Agency's comments and our evaluation of them are summarized below. 

Management Comments 

Recommendation 1 

The Associate Administrator, Office of Management and Administration agreed 

with the recommendation, and stated that he will revise and reissue the Agency 

Data Quality Plan to further delineate specific steps that must be taken to ensure 

data is properly reviewed for accuracy and completeness. The Associate 

Administrator also stated that he will provide training to the contracting 

specialists/ officers to reinforce this effort. 

GIG Response 

We consider management's comments to be responsive to the recommendation. 
9 

Recommendation 2 

The Associate Administrator, Office of Management and Administration agreed 

with the recommendation, and stated that in September 2009 the OBO contracted 

with LS3 to conduct an independent review of the SBA's FPDS data. He noted 

that LS3 's findings confirmed our audit report conclusion that the FY 2009 data is 

more accurate than prior year data. The Associate Administrator also stated that 

the Office of Management and Administration will make necessary adjustments to 

the Agency's Data Quality Plan to ensure continued improvement of FPDS data 

quality. He also stated that LS3 will conduct semi-annual data quality reviews to 

ensure on-going compliance with applicable guidance and to ensure the accuracy 

and completeness of the data. 

GIG Response 

We consider management's comments to be responsive to the recommendation. 

Recommendation 3 

The Associate Administrator, Office of Management and Administration agreed 

with the recommendation, and stated that the annual Performance Business 

Commitment Plans for contracting specialists/officers will include a critical 

performance element holding them accountable for the accuracy and completeness 

of FPDS data. 

GIG Response 

We consider management's comments to be responsive to the recommendation. 

ACTIONS REQUIRED 

Please provide your management decision for each recommendation on the 

attached SBA Forms 1824, Recommendation Action Sheet, within 30 days from 

the date of this report. Your decision should identify the specific action( s) taken 

or planned for each recommendation and the target date(s) for completion. 

We appreciate the courtesies and cooperation of the Small Business 

Administration during this review. If you have any questions concerning this 

report, please call me at (202) 205_[FOIAex2]or Riccardo R. Buglisi, Director, Business 

Development Programs Group, at (202) 205-[FOIAex2] 
10 

APPENDIX I. ATTRIBUTE SAMPLING METHODOLOGY AND 

PROJECTIONS 

For FY 2008, we reviewed a random sample of 36 of 85013 contract actions made 

during the fiscal year to estimate a FY 2008 FPDS error rate. To estimate a FY 

2009 FPDS error rate, we reviewed a random sample of 35 of 303 contract actions 

made. For each contract action, we reviewed 18 of 46 key data elements identified 

by OMB for assessing the accuracy ofFPDS data. We compared the information 

in FPDS to the information in SBA's contract file to determine the error rate for 

each data element. If the information for anyone of the 18 data elements did not 

match, we considered the overall contract action to be an error. FPDS data 

elements that required information, but were left blank, were also considered to be 

errors. In addition, if the Agency was unable to provide the file for a contract 

action in our sample, we counted the contract action as an error. 

In statistical sampling, the estimate of attributes in the population universe has a 

measurable precision or sampling error. The precision is a measure of the 

expected difference between the value found in the sample and the value of the 

same characteristics that would have been found if a 100-percent review had been 

completed using the same techniques. 

We calculated the population point estimates and the related lower and upper 

limits for the selected attributes, using the Defense Contract Audit Agency's "EZ 

Quant" software program, at a 90-percent confidence level. Projecting our sample 

results to the universe of 850 SBA contract actions, we estimated SBA's FY 2008 

FPDS error rate to be at least 80 percent. Our calculations for the FY 2008 error 

rates are shown in Table 1 and 2. Projecting our sample results to the universe of 

303 SBA contract actions, we estimated SBA's FY 2009 FPDS error rate to be 

approximately 88 percent. Our calculations for the FY 2009 rates are shown in 

Tables 3 and 4. 

13 The sample number is based on the FPDS data file as ofMay 3, 2009, which was the date the oro queried FPDS to 

identify the universe of contract actions for FY 2008. rn January 2009, SBA's certification included 855 contract 

actions for FY 2008. The difference between the universe from which the oro sampled and the number of contract 

actions that SBA certified to is attributed to the timing difference. 
11 
 

Table 1: OIG Calculations of SBA's FY 2008 FPDS Data Error Projections for Contract Actions 

Incomplete or Inaccurate Data 

Elements in Sample of 36 

Projected Number of Errors in Universe of 850 Contract 

Actions 

Lower Limit at 90-Percent 

Confidence 

Upper Limit at 90-Percent 

Confidence 

Number of Contract 

Actions with Errors 33 681 830 

Table 2: OIG Calculations of SBA's FY 2008 FPDS Data Error Projections by Data Element 

Data Elements 

Number of Incomplete or 

Inaccurate Data 

Elements in Sample of 36 

Projected Number of Errors in Universe of 850 Contract Actions 

Lower Limit at 90-Percent 

Confidence 

Upper Limit at 90-Percent 

Confidence 

1 

Procurement 

Identifier 3 20 168 

2 

Referenced 

Indefinite Delivery 

Vehicle 11 156 384 

3 Date Signed 11 156 384 

4 Completion Date 10 137 359 

5 Last Date to Order 5 49 228 

6 Action Obligation 6 65 255 

7 

Base and All Options 

Value 6 65 255 

8 

Funding Agency 

Identifier 3 20 168 

9 

Fees Paid for Use of 

illV 7 82 282 

10 Type of Contract 8 100 308 

11 

Description of 

Requirement 5 49 228 

12 

Principal NAICS 

Code 8 100 308 

13 DUNS 13 196 434 

14 

Place of 

Performance Zip 

Code 18 303 547 

15 Extent Competed 15 238 354 

16 Type of Set Aside 5 49 228 

17 

Contracting Officer's 

Business Size 

Selection 11 156 384 

18 illV/Award Type 11 156 384 
12 
 

Table 3: OIG Calculations of SBA's FY 2009 FPDS Data Error Projections for Contract Actions 

Incomplete or Inaccurate Data 

Elements in Sample of 35 

Projected Number of Errors in Universe of 303 Contract 

Actions 

Lower Limit at 90­

Percent Confidence 

Upper Limit at 90-Percent 

Confidence 

Number of 

Contract Actions 

with Errors 34 266 303 

Table 4: OIG Calculations of SBA's FY 2009 FPDS Data Error Rates by Data Element 

Data Elements 

Number of Incomplete or 

Inaccurate Data Elements in 

Sample of35 

Projected Number of Errors in Universe of 303 Contract 

Actions 

Lower Limit at 90-Percent 

Confidence 

Upper Limit at 90-Percent 

Confidence 

1 

Procurement 

Identifier 4 13 72 

2 

Referenced Indefinite 

Delivery Vehicle 8 38 111 

3 Date Signed 9 45 121 

4 Completion Date 5 18 82 

5 Last Date to Order 9 45 121 

6 Action Obligation 4 13 72 

7 

Base and All Options 

Value 9 45 121 

8 

Funding Agency 

Identifier 4 13 72 

9 

Fees Paid for Use of 

illV 4 13 72 

10 Type of Contract 7 32 102 

11 

Description of 

Requirement 5 18 82 

12 

Principal NAICS 

Code 15 89 174 

13 DUNS 8 38 111 

14 

Place ofPerformance 

Zip Code 15 89 174 

15 Extent Competed 11 58 139 

16 Type of Set Aside 6 25 92 

17 

Contracting Officer's 

Business Size 

Selection 8 38 111 

18 illVlAward Type 10 51 130 
13 

APPENDIX II. RESULTS OF DATA ANALYSIS REVIEW 

Table 1: OIG Results from Comparison of FPDS Data to SBA Contract Files for FY 2008 

1= Inaccurate 

B= Blank 

(incomplete) 

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15 

APPENDIX III. AGENCY COMMENTS 


U.S. SMALL BUSINESS ADMINISTRATION 


WASHINGTON, D.C. 20416 


DATE: 	 February 18,2010 

TO: Debra S. Ritt 

Assistant Inspector General for Auditing 

FROM: Darryl K. Hairston 

Associate Administrator 

Office of Management and Administration 

SUBJECT: 	 Draft Report on the Audit of SBA's Effort's to Improve the Quality of 

Acquisition Data in the Federal Procurement Data System, Project No. 

99010 

Thank you for providing the opportunity to comment on this draft report. 

The Small Business Administration (SBA) is committed to improving the quality of 

acquisition data in the Federal Procurement Data System (FPDS) and we appreciate your 

input and recommendations on the issues provided in your report. We are and will 

continue to take additional steps in our efforts to improve FPDS data quality. 

Following are the Agency's responses to the IG's recommendations: 

Recommendation # 1 - Either update the FY 2008 Data Quality Plan or revise the 

information notice to include explicit steps that will be taken to ensure data is 

reviewed for accuracy and completeness. 

We agree with this recommendation and will revise and reissue the Agency Data Quality 

Plan to further delineate specific steps that must be taken to ensure data is properly 

reviewed for accuracy and completeness. In addition, we will provide training to the 

contracting specialists/officers to reinforce this effort. 

Recommendation # 2 - Conduct an independent review to ensure that the Data 

Quality Plan or information notice requirements have been fully implemented. 

In September, 2009, the Office of Business Operations (OBO) contracted with LS3 to 

conduct an independent review of SBA FPDS data. Through this contract, LS3 provided 
16 

personnel with prior experience in federal acquisition and contract data analysis. These 

individuals were also provided training by SBA personnel specific to its expectations 

under the contract. 

We are pleased to note that their findings thus far confirm the conclusion in your report 

that the FY 2009 data is more accurate than prior year data. Based on their findings, as 

well as those you have noted, we will make the necessary adjustments to the Agency 

Data Quality Plan to ensure continued improvement in FPDS data quality. Additionally, 

LS3 will conduct semi-annual data quality reviews to ensure on-going compliance with 

applicable guidance and the accuracy and completeness of the data. 

Recommendation # 3 - Ensure that OBO contracting personnel are held accountable 

for the accuracy of FPDS data. 

As noted above, we are committed to improving the quality ofSBA's FPDS acquisition 

data and agree that contracting personnel should be held accountable for ensuring its 

accuracy and completeness. For this reason, the annual Performance Business 

Commitment Plan for each contracting specialist/officer will include a critical 

performance element setting forth this requirement. 

Thank you again for your review.