a

GAO

United States General Accounting Office

Report to the Chairman and Ranking 

Minority Member, Committee on Small 

Business, House of Representatives

May 2004 CONTRACT 

MANAGEMENT

Impact of Strategy to 

Mitigate Effects of 

Contract Bundling on 

Small Business Is 

Uncertain

GAO-04-454
In contrast to data captured in the Federal Procurement Data System 

(FPDS), only 4 of the 23 agencies held accountable by OFPP’s strategy 

reported a total of 24 bundled contracts in fiscal year 2002—far fewer than 

the 928 contracts identified as bundled in FPDS. Agency officials, after 

researching their contracts, determined that the bundling data in FPDS were 

miscoded due to confusion about the statutory definition of contract 

bundling, inadequate verification of information, and ineffective controls in 

the FPDS reporting process. For example, about 33 percent of FPDS 

contract actions identified as bundled were miscoded, because they were 

awarded to small businesses. By definition, a small business is essentially 

precluded from being awarded a bundled contract. The Department of 

Defense, which reported the second largest number of bundled contracts, 

determined that only 8 of the 109 contracts identified as bundled in FPDS 

met the statutory definition of a bundled contract. 

Although the actual number of bundled contracts reported by agencies is 

small, concerns about the effect of contract bundling on small businesses 

remain. According to OFPP, the primary goal of its strategy—and the 

resulting regulatory changes—is to increase small business federal 

contracting opportunities. Because new regulations have only recently been 

established, it is too early to determine whether agencies are achieving this 

goal. In addition, part of OFPP’s strategy—to identify and disseminate best 

practices for maximizing small business contract opportunities—has not 

been implemented. Yet even with time and guidance, it could be difficult to 

assess the effect of the recent regulations, in part because any increases in 

small business contracting opportunities could be attributed to other factors. 

For example, the largest procuring agencies have a history of seeking 

opportunities to increase small business contracting, and according to the 

General Services Administration, nearly 80 percent of Federal Supply 

Schedule contracts are awarded to small businesses. Further, because the 

regulations primarily relate to contract bundling—an activity most agencies 

report they do not engage in—the regulations may have little impact on 

increasing small business contracting opportunities. 

Nevertheless, certain regulatory changes—especially those related to 

oversight—have the potential to promote greater small business 

opportunities. For example, the new regulations require agencies to annually 

assess the extent to which small businesses receive a fair share of federal 

procurements, the adequacy of contract bundling documentation and 

justifications, and actions taken to mitigate the effects on small businesses 

of necessary and justified contract bundling. However, the new regulations 

do not establish metrics to measure agency accountability, and past data on 

bundling and its effects on small businesses have been limited and 

unreliable. Without metrics and reliable data, it will be difficult to gauge 

agency efforts to identify and eliminate contracts that are unnecessarily 

bundled. 

To achieve efficiencies and 

respond to procurement reforms, 

agencies have consolidated their 

procurement contracts—that is, 

combined existing smaller 

contracts into fewer larger 

contracts. To ensure contract 

bundling—a subset of contract 

consolidation—does not unfairly 

disadvantage small businesses, the 

President tasked the Office of 

Management and Budget (OMB) to 

develop a strategy that would hold 

agencies accountable for contract 

bundling practices. 

In October 2002, the Office of 

Federal Procurement Policy 

(OFPP) within OMB issued its 

strategy. 

This report discusses the extent to 

which contracts were bundled in 

fiscal year 2002 and assesses the 

potential effectiveness of 

regulatory changes that have 

recently resulted from OFPP’s 

strategy. 

GAO recommends that OMB (1) 

ensure agencies report uniform and 

reliable contract bundling data and 

(2) establish contract bundling 

metrics. OMB concurred with the 

first recommendation, but not the 

second. GAO believes metrics are 

needed to help determine how 

bundling affects small businesses. 

GAO also recommends that SBA 

disseminate best practices to 

maximize small business 

contracting opportunities, as 

required by the OFPP strategy. SBA 

concurred. 

www.gao.gov/cgi-bin/getrpt?GAO-04-454.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact David Cooper 

at (202)512-4125 or cooperd@gao.gov. 

Highlights of GAO-04-454, a report to the 

Committee on Small Business, House of 

Representatives 

May 2004

CONTRACT MANAGEMENT 

Impact of Strategy to Mitigate Effects of 

Contract Bundling Strategy on Small 

Business Is Uncertain 
Page i GAO-04-454 Contract Management 

Letter 1

Results in Brief 2

Background 4

Agency Data Are Inconsistent with FPDS Data 6

Effect of Regulatory Changes on Small Business Contracting 

Opportunities Will Be Difficult to Gauge, Although Certain 

Changes May Yield Increases 7

Regulatory Changes Do Not Establish Metrics and Information to 

Monitor Contract Bundling Trends and Effects 11

Conclusions 12

Recommendations for Executive Action 12

Agency Comments and Our Evaluation 12

Scope and Methodology 13

Appendix I Status of Nine Action Items Contained in OFPP’s 

Report 16 

Appendix II Summary of Agency Responses to OFPP-Directed 

Metrics 17 

Appendix III Summary of Contract Bundling Rule Changes 19 

Appendix IV Comments from the Office of Management and 

Budget 21 

Related GAO Products 22 

Tables 

Table 1: Status of Action Items Contained in OFPP’s Contract 

Bundling Strategy 16

Table 2: Summary of Agency Responses to OFPP-Directed Metrics 

for Fiscal Year 2002 17

Contents 
Page ii GAO-04-454 Contract Management 

Table 3: Bundling Regulations, before and after Amendments 19

Abbreviations 

AID Agency for International Development 

DHS Department of Homeland Security 

DOD Department of Defense 

DOE Department of Energy 

EPA Environment Protection Agency 

FAR Federal Acquisition Regulation 

FPDS Federal Procurement Data System 

GSA General Services Administration 

HHS Health and Human Services 

HUD Housing and Urban Development 

NASA National Aeronautics and Space Administration 

NSF National Science Foundation 

OFPP Office of Federal Procurement Policy 

OMB Office of Management and Budget 

OSDBU Office of Small and Disadvantaged Business Utilization 

PMC President’s Management Council 

SBA Small Business Administration 

SSA Social Security Administration 

VA Veteran’s Administration 

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Page 1 GAO-04-454 Contract Management 

May 27, 2004 

The Honorable Donald A. Manzullo 

Chairman 

The Honorable Nydia M. Velazquez 

Ranking Minority Member 

Committee on Small Business 

House of Representatives 

Each year, the federal government spends billions of dollars to 

procure goods and services ranging from paper clips to the development 

of complex space vehicles. To achieve efficiencies while responding 

to significant procurement reforms and acquisition workforce 

reductions, agencies have increasingly consolidated their procurement 

contracts—that is, combine existing smaller contracts into fewer 

larger contracts. However, concerns have been raised that contract 

bundling—consolidating contracts to such an extent that they may 

preclude small businesses from competing—unnecessarily limits federal 

contracting opportunities for small businesses. 

To ensure contract bundling does not unfairly disadvantage small 

businesses, the President tasked the Office of Management and Budget 

(OMB) to develop a strategy that would hold agencies accountable for 

contract bundling practices. In October 2002, OMB’s Office of Federal 

Procurement Policy (OFPP) issued “Contract Bundling: A Strategy for 

Increasing Federal Contracting Opportunities for Small Business.” The 

strategy contains action items designed to change contract bundling 

regulations, hold 23 agencies accountable for eliminating unnecessary 

contract bundling, mitigate the effects of necessary bundling, and increase 

small business contracting opportunities. OFPP also required each agency 

to submit quarterly reports through October 31, 2003, documenting their 

progress in implementing the strategy. 

To provide a better understanding of the extent to which contract 

bundling occurs and the effect of OFPP’s strategy on small business 

federal contracting opportunities, you asked us to (1) identify the number 

of contracts the 23 accountable agencies reported as bundled in fiscal year 

2002, and (2) assess the potential effectiveness of the regulatory changes 

to increase small business contracting opportunities. 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-454 Contract Management 

To identify the number of bundled contracts, we reviewed agency data 

submitted to OFPP, as required by the OFPP strategy, and data in the 

Federal Procurement Data System (FPDS), the federal repository for 

contracting data.1

 When discrepancies surfaced between the two sets of 

data, we asked agency officials for an explanation. To assess the potential 

effectiveness of regulatory changes to increase small business contracting 

opportunities, we reviewed OFPP-strategy-required reports and obtained 

the views of officials from agencies that, collectively, accounted for over 

85 percent of the fiscal year 2002 federal procurement expenditures. A 

more detailed discussion of our scope and methodology is at the end of 

this letter. 

We conducted our review from April 2003 to February 2004 in accordance 

with generally accepted government auditing standards. 

Four of the 23 agencies held accountable by OFPP’s strategy reported 

a total of 24 bundled contracts in fiscal year 2002; of the remaining 

19 agencies, 16 reported no bundled contracts, and 32

 did not provide 

information on the number of bundled contracts. The small number of 

agency-reported bundled contracts is inconsistent with the 928 contracts3

identified as bundled in the FPDS. Agency officials, after researching their 

contracts, determined that the bundling data in FPDS were miscoded due 

to confusion about the definition of contract bundling, inadequate 

verification of information, and ineffective controls in the FPDS reporting 

process.4

 For example, about 33 percent of the FPDS fiscal year 2002 

contract actions shown as being bundled were awarded to small 

 1

 FPDS contains detailed information on contract actions over $25,000 and summary data 

on procurements of less than $25,000. The system is intended to identify who bought what, 

from whom, for how much, when, and where. On October 1, 2003, the successor system to 

FPDS—FPDS Next Generation—became operational. 

2

 The Agency for International Development and the Department of Justice did not report. 

In addition, the Department of Homeland Security, established by law in November 2002 

(Pub. L. 107-296, Nov. 25, 2002), did not have fiscal year 2002 FPDS data. 

3

 The 928 bundled contracts in FPDS represent contracts associated with 2,404 contract 

actions coded as bundled in fiscal year 2002. A fiscal year 2002 contract action could have 

been associated with a contract awarded in fiscal year 2002, or a prior fiscal year. 

4

 We have previously reported on FPDS data inaccuracies, most recently in December 2003. 

See Reliability of Federal Procurement Data, GAO-04-295R (Washington, D.C.: 

Dec. 30, 2003). 

Results in Brief 
Page 3 GAO-04-454 Contract Management 

businesses, an unlikely occurrence, since a small business, by definition, is 

essentially precluded from being awarded a bundled contract. 

Despite the limited number of bundled contracts reported by agencies, 

concerns that small businesses may be losing federal contracting 

opportunities remain. According to OFPP, the primary goal of its 

strategy—and the resulting regulatory changes—is to increase small 

business federal contracting opportunities. Because the new regulations 

have only recently been established, it is too early to determine whether 

agencies are achieving this goal. In addition, the Small Business 

Administration (SBA), as of February 25, 2004, has not identified and 

disseminated best practices—as required by OFPP’s strategy—to help 

agencies maximize small business contract opportunities. However, even 

with time and guidance, it will likely be difficult to assess the effect of the 

recent changes to the regulations, in part because any increases in small 

business contracting opportunities could be attributed to factors other 

than regulatory changes. For example, we found that the largest procuring 

agencies have a history of seeking opportunities to increase small business 

contracting opportunities, which could explain any future increases. 

Further, because the regulations primarily relate to contract bundling and 

agency-reported data show that bundling is limited, the regulations’ impact 

on increasing small business contracting opportunities may also be 

limited. 

Nevertheless, certain regulatory changes—especially those related to 

oversight—have the potential to promote greater small business 

opportunities. For example, the regulations now require agencies’ Office 

of Small and Disadvantaged Business Utilization (OSDBU)—an agency’s 

advocate for small business—to conduct annual assessments of (1) the 

extent to which small businesses receive a fair share of federal 

procurements, (2) the adequacy of contract bundling documentation and 

justifications, and (3) the adequacy of actions taken to mitigate the effects 

on small businesses of necessary and justified contract bundling. 

However, the regulations do not establish metrics to measure the extent to 

which contract bundling is occurring, or the extent to which bundling 

impacts small business contracting opportunities. Consequently, it will be 

difficult to gauge agency efforts to identify and eliminate contracts that are 

unnecessarily bundled and, thereby, increase small business federal 

contracting opportunities. This weakness is not new; past data on 
Page 4 GAO-04-454 Contract Management 

bundling and the effects of consolidating requirements on small 

businesses have been limited and unreliable.5

To improve the oversight of contract bundling, we are recommending that 

the Director, Office of Management and Budget, (1) ensure that FPDS and 

agency reporting processes provide uniform and reliable contract bundling 

information and (2) direct the Administrator, OFPP, to establish metrics to 

measure contract bundling and the extent to which contract bundling 

impacts small business federal contracting opportunities. In commenting 

on a draft of this report, OMB concurred with the first recommendation, 

but not the second. The basis of OMB’s non-concurrence is their concern 

that implementation of the recommendation envisions new governmentwide reporting and record keeping requirements outside of FPDS, which is 

duplicative and possibly labor-intensive. OMB suggested, in place of our 

recommendation, that it work with the SBA to explore possible inclusion 

of new reporting requirements in FPDS that would track the impact of 

bundling on contracting opportunities for small businesses. The purpose 

of our recommendation is to establish metrics, not a new reporting and 

record keeping system outside of FPDS. OMB’s position, that it work with 

SBA to explore possible inclusion of new reporting requirements in FPDS, 

does not address the need for metrics. We believe metrics are needed to 

help determine how bundling affects small businesses. Without metrics to 

measure contract bundling and its impact, the information needed to 

ensure agency accountability to eliminate unnecessary contract bundling, 

mitigate the effects of necessary bundling, and increase small business 

contracting opportunities will be limited or unknown. 

We are also recommending that the SBA Administrator expedite 

dissemination of best practices for maximizing small business contract 

opportunities. SBA concurred with this recommendation. 

Over the last decade, changes in procurement practices, acquisition 

workforce reductions, and legislative changes have challenged agencies 

to create efficiencies in their acquisition processes. By consolidating 

contracts—that is, combining existing requirements into fewer contracts—

agencies can streamline the procurement process and thereby reduce 

acquisition and administrative complexity and cost. A subset of contract 

 5

 Small Businesses: Limited Information Available on Contract Bundling’s Extent and 

Effects, GAO/GGD-00-82 (Washington, D.C.: Mar. 31, 2000). 

Background 
Page 5 GAO-04-454 Contract Management 

consolidation is contract bundling. The Small Business Reauthorization 

Act of 1997 defines a bundled contract as one that consolidates two or 

more procurement requirements that previously were provided or 

performed under separate, smaller contracts into a solicitation for offers 

for a single contract that is likely to be unsuitable for award to a small 

business. For example, a small business might be able to perform certain 

maintenance tasks, such as plumbing and carpentry at a single government 

facility. However, if a solicitation were to add paving and electrical repairs 

and also expand the performance site to more than one regional area, such 

a solicitation may be beyond the capability of any small business.6

 In sum, 

a consolidated contract can be suitable for award to a small business and a 

bundled contract is not. 

To help ensure that contract bundling does not unnecessarily disadvantage 

small businesses, the Small Business Reauthorization Act of 1997 requires 

that to the maximum extent practicable, agencies are to avoid contract 

bundling unless they can demonstrate “measurably substantial benefits,” 

such as cost savings,7

 quality improvement, reduction in acquisition cycle 

times, or better terms and conditions. 

OFPP’s strategy to address contract bundling and increase federal 

contracting opportunities for small businesses contains nine action items 

designed to change contract bundling regulations, hold 23 agencies 

accountable to eliminate unnecessary contract bundling, mitigate the 

effects of necessary bundling, and increase small business contracting 

opportunities. Most action items were incorporated into Federal 

 6

 The Small Business Reauthorization Act of 1997 lists several factors that may result in a 

contract being unsuitable for award to a small business: (1) the diversity, size, or 

specialized nature of the elements of the performance specified; (2) the aggregate dollar 

value of the anticipated award; (3) geographical dispersion of the contract performance 

sites; and (4) any combination of the above. Pub.L. 105-135, section 412. 

7

 The regulations implementing the act stated that for contracts of $75 million or less, 

benefits were equivalent to 10 percent of the contract value (including options); for 

contracts over $75 million, benefits were equivalent to 5 percent of contract value 

(including options) or $7.5 million, whichever is greater. Further, agencies were required to 

justify “substantial bundling,” defined as any bundled contract valued at $10 million or 

more, by also (1) identifying the specific benefits anticipated to be derived from bundling; 

(2) including an assessment of the specific impediments to small business participation 

that result from bundling, (3) specifying actions designed to maximize small business 

participation as contractors, (4) specifying actions designed to maximize small business 

participation as subcontractors, and (5) including a specific determination that the 

anticipated benefits of the proposed bundled contract justify its use. FAR 7.107(b), (e); 

13 C.F.R. 125.2 (d)(5), (7). 
Page 6 GAO-04-454 Contract Management 

Acquisition Regulation (FAR) and SBA regulations on October 20, 2003. 

The nine action items and their status are described in appendix I. 

As part of implementing its strategy, OFPP also required OSDBUs from the 

23 agencies to report quarterly on their implementation of the nine action 

items. OSDBUs have a central role in monitoring contract bundling 

activity. They are responsible for overseeing their agency’s functions and 

duties related to the awarding of contracts and subcontracts to various 

types of small businesses. Moreover, the Congress intended that OSDBU 

directors serve in their respective agencies as advocates for these 

businesses. 

In their reports to OFPP, only 4 of the 23 accountable agencies reported 

that they had bundled contracts for fiscal year 2002. Further, the four 

agencies reported only a total of 24 bundled contracts—far fewer than the 

928 contracts reported as bundled in FPDS. Of the remaining 19 agencies, 

16 reported no bundled contracts, and 3 did not provide contract bundling 

information. (See app. II for details on contract bundling activity reported 

by agencies.) 

Through our review of FPDS bundling data, we found that much of the 

data are inaccurate, causing FPDS to record more bundled contracts and 

actions than reported by the agencies to OFPP. For example, about 

33 percent of FPDS-coded bundled contract actions were also shown as 

being awarded to small businesses. By definition, a small business is 

essentially precluded from being awarded a bundled contract. According 

to OSDBU officials at the Departments of Defense (DOD), Veterans 

Affairs, Interior, Health and Human Services, and Transportation—the five 

agencies with the largest number of FPDS-reported bundled actions in 

fiscal year 2002—the inaccuracies in FPDS were coding errors made as 

the result of confusion about the statutory definition of contract bundling, 

inadequate verification of data, and ineffective controls in the FPDS 

reporting process. For example, through a review of Interior’s 

80 contracting offices, Interior’s OSDBU found that all had erroneously 

coded contracts as bundled. Interior’s OSDBU attributed the coding errors 

to confusion over the statutory definition of a bundled contract. DOD 

similarly had its military departments and defense agencies review the 

109 contracts originally identified as bundled, and they determined that 

only 8 out of the 109 contracts met the statutory definition of a bundled 

contract. The 101 miscoded contracts were primarily the result of 

confusion about the definition of bundling and lack of controls and 

oversight in the FPDS reporting system. 

Agency Data Are 

Inconsistent with 

FPDS Data 
Page 7 GAO-04-454 Contract Management 

Inaccuracies in FPDS data are a long-standing problem, which we have 

previously reported on—most recently on December 30, 2003, when we 

issued a letter to OMB expressing our concern that continuing problems 

with the reliability of FPDS data could adversely impact decision-making 

and oversight of the federal procurement system.8

 We identified a number 

of examples where poor data limited our ability to assess procurement 

programs and found that many of the FPDS data problems, including 

inaccurate data on bundling activity, were the result of confusion over 

information requirements, which led to data entry mistakes by agency 

contracting officials. We made recommendations to improve the reliability 

of FPDS data. OMB generally concurred with our recommendations and, 

as of March 25, 2004, are considering actions to respond to them. 

According to OFPP, the primary goal of its strategy—and the recent FAR 

changes—is to increase small business federal contracting opportunities. 

However, it will be difficult to determine whether any increases in small 

business opportunities are the result of the recent regulatory changes or 

other factors, such as continuing agency efforts. While some aspects of the 

changes have the potential to help achieve desired goals, the new 

regulations do not provide for metrics to measure agency accountability 

for improving small business participation in federal procurement. 

Despite OFPP’s stated goal for its strategy—to increase small business 

federal contracting opportunities—several factors will make it difficult to 

assess the effect of the regulatory changes on such opportunities. First, 

because contract bundling FAR and SBA rules were not amended until 

October 2003, it is too early to determine whether the regulations have 

achieved desired outcomes. Further, SBA has yet to disseminate best 

practices to agencies—an action item in OFPP’s strategy. One key purpose 

of the best practices is for agencies to incorporate them into training 

courses and materials. In January 2003, SBA requested agency senior 

procurement executives to provide proven best practices to optimize 

prime and subcontracting opportunities for small businesses. According to 

SBA officials, that input has been received and a best practices guide has 

been drafted. SBA, however, has not established a schedule to disseminate 

the guide, and until such time, agencies can do little to respond to this 

OFPP strategy action item. 

 8

 See GAO-04-295R. 

Effect of Regulatory 

Changes on Small 

Business Contracting 

Opportunities Will Be 

Difficult to Gauge, 

Although Certain 

Changes May Yield 

Increases 
Page 8 GAO-04-454 Contract Management 

Second, it will be difficult to determine whether any increased 

opportunities are the result of the regulatory changes or other 

factors, such as continuing agency efforts to address bundling. DOD, 

the Department of Energy (DOE), the National Aeronautics and 

Space Administration (NASA), and the General Services Administration 

(GSA)—which together procured about 80 percent of the federal 

government’s goods and services in fiscal year 2002—each have a history 

of seeking opportunities to increase small business contracting 

opportunities. Since 1982, DOD has issued five policy memoranda on small 

business participation in consolidated and bundled contracts. The first 

memorandum directed that functions currently performed by small 

businesses should not be consolidated and that, unless there were 

overriding national security interests, future solicitations should be 

packaged so as not to preclude performance by small businesses. The 

most recent policy memorandum, dated January 17, 2002, requires 

(1) review of multiple award indefinite-delivery, indefinite-quantity 

contracts to avoid unnecessary bundling9

 and (2) consideration of small 

business participation from acquisition planning through program 

execution. A benefit analysis guidebook was disseminated with the 

January 2002 memorandum that includes guidance on avoiding contract 

bundling, outlines how to perform a benefit analysis to justify necessary 

bundling, and addresses how to mitigate the impact on small businesses 

when a bundled contract has been determined to be necessary and 

justified. Further, the National Defense Authorization Act for Fiscal Year 

200410 imposes additional requirements on senior procurement executives 

to ensure that small businesses are given appropriate opportunities to 

participate in consolidated acquisitions in excess of $5 million—a 

threshold that is $2 million lower than the substantial bundling threshold 

established in the new regulations. 

The other three agencies also have a history of efforts to address contract 

bundling and increase small business contracting opportunities. For 

example, in 1992, NASA put a policy in place that required its contracting 

offices contemplating contract consolidation to get concurrence from the 

NASA Chief of Staff at Headquarters, who was required to seek advice 

 9

 Indefinite delivery, indefinite quantity contracts are used when an agency does not know 

the precise quantity of supplies or services to be provided under a contract. As the agency 

identifies a specific need for goods or services, it issues orders for individual requirements, 

which cannot exceed the maximum amount specified in the contract. 

10 Pub. L. 108-136, section 801. 
Page 9 GAO-04-454 Contract Management 

from the NASA OSDBU. In 2000, NASA required contract bundling 

justification, review, and approval of orders from Federal Supply 

Schedule contracts,11 governmentwide acquisition contracts, or other 

indefinite-delivery contracts. NASA further imposed the substantial 

bundling documentation requirements, as well as Headquarters Office of 

Procurement review, on each proposed bundling activity expected to 

exceed $5 million in total value—half the substantial bundling threshold of 

$10 million in effect at that time.12 DOE’s procurement executive has 

similarly issued acquisition letters dating back to April 2000 that focused 

on how to maximize small business opportunities in federal contracting. 

According to GSA officials, GSA’s Multiple Award Schedule Program has, 

for several years, allowed Federal Supply Schedule contractors to team up 

to deliver a total solution to customer agencies from multiple industries.13

Such arrangements have the potential to enhance the ability of small 

businesses to capture all or a portion of a customer’s total requirement. 

Further, the Federal Supply Schedule, which GSA administers, also 

contains a strong small business presence, with approximately 78 percent 

of Federal Supply Schedule contracts awarded to small businesses, 

according to GSA. 

Finally, the recent regulations relate primarily to contract bundling—an 

activity most agencies report they do not engage in. The regulations, for 

example, are designed to require agency officials to review proposed 

acquisitions to preclude unnecessary bundling and mitigate the effects of 

necessary contract bundling. However, because 16 of the 23 agencies14

held accountable by the OFPP strategy reported that they had no bundled 

contracts in fiscal year 2002 and the bundling that was reported was 

limited, it is unclear to what extent the regulations will help increase small 

business contracting opportunities at these agencies. 

 11 The Federal Supply Schedule, administered by GSA, is designed to provide federal 

agencies with a simplified process for obtaining millions of commonly used commercial 

supplies and services at prices associated with volume buying. The program consists of 

single award schedules with one supplier and multiple award schedules, in which GSA 

awards contracts to multiple companies supplying comparable services and products. 

12 The new bundling regulations lowered the substantial bundling threshold for NASA to 

$5 million. 

13 Schedule contractors may propose a team solution or customer agencies may solicit for a 

team solution. 

14 The Agency for International Development and Justice did not report. In addition, the 

Department of Homeland Security, established by law in November 2002 (Pub. L. 107-296, 

Nov. 25, 2002), did not have fiscal year 2002 FPDS data. 
Page 10 GAO-04-454 Contract Management 

Despite the uncertainties regarding the effect of the recent regulatory 

changes on small business contracting opportunities, certain changes in 

the FAR and SBA regulations15 have the potential to increase such 

opportunities—specifically those related to mandatory coordination of 

agency officials and increased oversight. These regulatory changes were 

designed to preclude unnecessary contract bundling and mitigate the 

effects of justified bundling on small contractors. For example, the FAR 

now requires OSDBUs to conduct periodic reviews to assess (1) the extent 

to which small businesses are receiving their fair share of federal 

procurements under the Small Business Act, (2) the adequacy of contract 

bundling documentation and justification, and (3) the actions taken to 

mitigate the effects of necessary and justified bundling on small 

businesses. OSDBUs are required to submit their assessments to the head 

of their agency and the SBA Administrator. 

The FAR and SBA regulations now require agencies to assess contractor 

performance against small business goals identified in subcontracting 

plans in contracts that require a subcontracting plan.16 This action requires 

agencies to systematically review contracts of $500,000 for products or 

services and contracts of $1 million for construction and ensure they 

comply with required small business subcontracting plans. Further, the 

new regulations established agency-specific dollar thresholds to invoke 

mandatory coordination with agency small business specialists.17 The new 

thresholds are $7 million for DOD; $5 million for DOE, GSA, and NASA; 

and $2 million for all other agencies. The regulations also specify that 

multiple award indefinite quantity contracts and orders placed against 

Federal Supply Schedule contracts and governmentwide acquisition 

contracts are now subject to bundling requirements and restrictions. 

Finally, SBA now requires SBA procurement center representatives18 to 

ensure that small business participation is maximized through teaming 

arrangements by working with agency small business specialists and 

 15 See appendix III for table summarizing regulatory changes. 

16 FAR 42.1502; 13 CFR 125.2(e)(1)(iii). 

17 Small business specialists are agency personnel that assist small businesses with federal 

contracting. 

18 Procurement center representatives are SBA personnel whose duties include assisting 

small businesses in obtaining federal contracts and monitoring acquisitions to ensure 

compliance with small business requirements. These representatives are located at various 

SBA procurement area offices and federal buying centers around the country. 
Page 11 GAO-04-454 Contract Management 

OSDBUs, as early in the acquisition process as practical. The new SBA 

regulation is designed to (1) allow small business teams to compete for 

acquisitions when contract bundling is determined to be necessary, and 

hence, unsuitable for individual small businesses to perform and 

(2) remove obstacles small businesses face in forming teams, such as the 

relatively limited time available to respond to solicitations. 

Over the last several years, we have been asked to review acquisition 

reforms and initiatives to determine whether they are achieving desired 

outcomes. Determining whether desired outcomes are being achieved is 

dependent on metrics and reliable information. However, as we testified 

in March 2003 before the Senate Committee on Small Business and 

Entrepreneurship,19 agencies often lack metrics and reliable information to 

enable the Congress and the President to ensure agency accountability for 

improving small business participation in federal procurement. Despite 

our findings, the new contract bundling regulatory changes do not 

establish metrics or identify the information needed to determine the 

extent to which agencies bundle contracts and measure the impact of 

bundling on small businesses—a weakness exacerbated by the fact that 

past data on bundling has been limited and unreliable.20

Recording and distributing timely and accurate information on contract 

bundling is key to ensuring accountability, monitoring contract bundling 

trends, and adjusting practices as warranted. Although agency OSDBUs 

must now submit annual reports to assess the small business share of 

federal procurements, the adequacy of bundling documentation, and 

actions taken to mitigate the effects of bundling to their agency head and 

the SBA Administrator, there is no requirement for metrics or specific 

bundling-related information. Without metrics and information to measure 

contract bundling and its impact, annual assessments will likely be 

process oriented, citing, for example, senior executive memos stressing 

commitment to eliminate unnecessary contract bundling and identifying 

who is accountable to optimize contracting opportunities for small 

businesses. Potential metrics and information OSDBUs could use in their 

required annual reports to monitor contract bundling trends and impacts 

include (1) the number and dollar value of bundled contract actions and 

 19 See Small Business Contracting: Concerns About the Administration’s Plan to Address 

Contract Bundling Issues, GAO-03-559T (Washington, D.C.: Mar. 18, 2003). 

20 See Small Businesses: Limited Information Available on Contract Bundling’s Extent 

and Effects, GAO/GGD-00-82 (Washington, D.C.: Mar. 31, 2000). 

Regulatory Changes 

Do Not Establish 

Metrics and 

Information to 

Monitor Contract 

Bundling Trends 

and Effects 
Page 12 GAO-04-454 Contract Management 

contracts, (2) benefit analyses (dollars saved) to justify why contracts are 

bundled, (3) the number of small businesses losing federal contracts 

because of bundling, (4) how bundled contracts complied with agencies 

subcontracting plans, and (5) how mitigation actions, such as teaming 

arrangements, provided increased contracting opportunities to small 

businesses. 

As we have reported over the past several years, a lack of reliable data on 

contract bundling activity at federal agencies has limited the Congress’ 

and the President’s ability to accurately assess the extent of contract 

bundling governmentwide and its effect on small business contracting 

opportunities. Although the most recent regulatory changes have the 

potential to increase contracting opportunities for small businesses, until 

such time that OFPP takes action to improve FPDS data reliability and 

establish metrics to measure contract bundling activity, the extent to 

which contract bundling impacts small business federal contracting 

opportunities will continue to be limited or unknown. 

We are recommending that the Director, Office of Management and 

Budget, 

• ensure that planned FPDS reliability improvements include accurate 

agency reporting to provide uniform and reliable contract bundling 

information and 

• direct the Administrator, OFPP, to establish metrics to measure 

contract bundling and the extent to which contract bundling impacts 

contracting opportunities for small businesses. 

We are also recommending that the Administrator, SBA, expedite the 

dissemination of best practices to maximize small business contract 

opportunities for incorporation into agencies’ training courses, as required 

by the OFPP strategy. 

In March 2004, we requested comments on a draft of this report from the 

Director of OMB and from the Administrator, SBA. 

In written comments, OMB concurred with the first recommendation, but 

not the second. OMB expressed concern with our recommendation that 

OFPP be directed to establish metrics to measure contract bundling and 

the extent to which contract bundling impacts contracting opportunities 

for small businesses. OMB is concerned that our recommendation 

Conclusions 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
Page 13 GAO-04-454 Contract Management 

envisions that OMB establish new, governmentwide reporting and 

record-keeping requirements outside of FPDS, which is duplicative and 

possibly labor-intensive. In addition, OMB suggested that the our 

recommendation be revised to require OFPP to work with SBA to explore 

possible inclusion of new reporting requirements in FPDS that would 

track the impact of bundling on contracting opportunities for small 

businesses. 

We believe OMB’s concern is unfounded. The purpose of our 

recommendation is to establish contract bundling metrics, not a new 

reporting and record-keeping system outside of FPDS. The establishment 

of bundling metrics, together with the implementation of our 

recommendation that OMB ensure that its planned FPDS reliability 

improvements include accurate agency reporting of contract bundling 

information, does not require a new reporting and record-keeping system 

outside of FPDS. 

We believe OMB’s suggestion that our recommendation be revised to 

explore possible inclusion of new reporting requirements to track the 

impact of bundling on small businesses will not provide the Congress 

sufficient information to understand the effects of bundling on small 

businesses, unless metrics are established. As stated in our report, 

determining whether acquisition reforms and initiatives are being achieved 

is dependent on metrics. Without metrics to measure contract bundling 

and its impact, the information needed to ensure agency accountability to 

eliminate unnecessary contract bundling, mitigate the effects of necessary 

bundling, and increase small business contracting opportunities will be 

limited or unknown. 

In official oral comments on the report, staff from SBA concurred with the 

SBA recommendation and had no other comments on the report.

To identify the number of contracts agencies reported as bundled in fiscal 

year 2002, we reviewed the data submitted by agencies in their reports to 

OFPP. We also analyzed fiscal year 2002 contract actions coded as 

bundled in FPDS to compare information reported by the agencies. Where 

large discrepancies existed between agency and FPDS data, we contacted 

agency OSDBU officials to obtain an explanation. Those agencies were the 

Veterans Administration and the Departments of Defense, Health and 

Human Services, Interior, and Transportation. We did not verify the 

agency-reported data used in this report. Its reliability is dependent on 

OSDBU review of their agency contracts. We believe the data OSDBUs 

Scope and 

Methodology 
Page 14 GAO-04-454 Contract Management 

reported to OFPP to be generally reliable because OSDBUs (1) have a 

central role in monitoring contract bundling activity, (2) are responsible to 

oversee their agency’s functions and duties related to the awarding of 

contracts and subcontracts to various types of small businesses, and 

(3) researched and then explained the difference between the bundling 

data they reported to OFPP and what is in FPDS. 

To assess the potential effectiveness of the OFPP strategy and the 

regulatory changes resulting from it, we reviewed the four required 

quarterly reports submitted by the agencies to OFPP. Those reports were 

to describe agency efforts to implement the strategy. In addition, we met 

with procurement and OSDBU officials from five federal agencies—DOD, 

DOE, GSA, NASA, and the Veterans Administration—that collectively 

spent over 85 percent of the total procurement dollars in fiscal year 2002. 

We obtained their views on the impact of the strategy and subsequent 

regulatory changes. We also contacted officials from the OSDBUs of the 

remaining 18 agencies held accountable by the strategy to obtain their 

views on its implementation. Finally, we met with officials from OFPP and 

SBA to gain a better understanding of the objectives of the strategy, as 

well as a governmentwide perspective on contract bundling and its effect 

on small business opportunities within the federal procurement 

community. 

We also reviewed applicable contract bundling laws, policies, and 

regulations. 

As agreed, unless you publicly announce its contents earlier, we plan no 

further distribution of this report until 30 days after the date of this letter. 

At that time, we will send copies of this report to the Administrators of the 

OFPP and SBA, and the heads of the 23 executive agencies held 

accountable by OFPP’s strategy. We will also provide copies to others on 

request. In addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov. 
Page 15 GAO-04-454 Contract Management 

If you or your staff have questions concerning this report, please 

contact me at (202) 512-4841 or by e-mail at cooperd@gao.gov, or 

James Fuquay at (937) 258-7963. Key contributors to this report were 

Johnetta Gatlin-Brown, Daniel Hauser, Julia Kennon, Mary Jo Lewnard, 

Sylvia Schatz, and Karen Sloan. 

David E. Cooper 

Director 

Acquisition and Sourcing Management 
Appendix I: Status of Nine Action Items 

Contained in OFPP’s Report 

Page 16 GAO-04-454 Contract Management 

In October 2002 in response to the President’s tasking to develop a 

strategy to hold agencies accountable for contract bundling practices, the 

Office of Federal Procurement Policy (OFPP) issued “Contract 

Bundling: A Strategy for Increasing Federal Contracting Opportunities 

for Small Business.” The status of the strategy’s nine action items, as of 

February 25, 2004, is presented below. 

Table 1: Status of Action Items Contained in OFPP’s Contract Bundling Strategy 

Action item Status 

Ensure accountability of senior agency management for 

improving contracting opportunities for small business 

Twenty-three agencies were required to report to the Office of Management 

and Budget’s (OMB) Deputy Director for Management on the status of their 

efforts to address contract bundling issues on a quarterly basis from 

January 31, 2003, until October 31, 2003. Quarterly reports are no longer 

required. 

Ensure timely and accurate reporting of contract 

bundling information through the President’s 

Management Council (PMC) 

PMC, composed of deputy secretaries and administrators from the major 

agencies, was tasked with assisting OMB with monitoring the status of 

agency efforts to address contract bundling. We did not obtain access to 

PMC documentation. 

Require contract bundling reviews for task and delivery 

orders under multiple award contract vehicles 

The Federal Acquisition Regulation (FAR) and Small Business 

Administration (SBA) regulations were amended on October 20, 2003. 

Require agency review of proposed acquisitions above 

specified dollar thresholds for unnecessary and 

unjustified contract bundling 

The FAR and SBA regulations were amended on October 20, 2003. 

Require identification of alternative acquisition 

strategies for the proposed bundling of contracts above 

specified thresholds and written justification when 

alternatives involving less bundling are not used 

The FAR and SBA regulations were amended on October 20, 2003. 

Mitigate the effects of contract bundling by 

strengthening compliance with subcontracting plans 

The FAR and SBA regulations were amended on October 20, 2003. 

Mitigate the effects of contract bundling by facilitating 

the development of small business teams and joint 

ventures 

SBA regulations were amended on October 20, 2003. 

Identify best practices for maximizing small business 

opportunities 

In January 2003, SBA requested agencies to provide proven “best practices” 

to optimize prime and subcontracting opportunities for small businesses. The 

intent of this action item was to disseminate best practices for incorporation 

into agencies training courses. On February 25, 2004, SBA advised us that a 

draft Best Practices Guide had not been approved and a schedule for its 

approval had not been established. 

Dedicate agencies’ Offices of Small and Disadvantaged 

Business Utilization (OSDBU) to the President’s Small 

Business Agenda 

OSDBUs must now submit annual bundling justification reports to their 

agency head and the SBA Administrator. 

Source: GAO analysis of OFPP contract bundling strategy and regulations. 

Appendix I: Status of Nine Action Items 

Contained in OFPP’s Report 
Appendix II: Summary of Agency Responses 

to OFPP-Directed Metrics 

Page 17 GAO-04-454 Contract Management 

OFPP required OSDBUs from 23 agencies to report quarterly on 

implementation of OFPP’s contract bundling strategy. Table 2 summarizes 

agency responses to the OFPP-directed metrics for fiscal year 2002. 

Table 2: Summary of Agency Responses to OFPP-Directed Metrics for Fiscal Year 2002 

Dollars in millions 

 Contracts/orders at or above agency specific dollar thresholdsa

 Review by OSDBU 

Review by 

SBSb

Agency 

Number of 

bundled 

contracts 

Total 

number 

Total 

dollars

Percentage of total agency 

procurement dollars for 

FY 2002 Number Percent Number Percent

Agriculture 0 308 $1,400.0 35.60 59 19 205 67

AID N/R 56 410.5 38.75 45 c 0n 0n

Commerce 0 89 436.5 27.00 24 27 65 73

DHS N/A N/A N/A N/A N/A N/A N/A N/A

DOD 8 3,397 131,018.2 72.50 d d 3,319 98e

Education 0 24 79.0 7.50 21 88 21 88

Energy 0 7 61.8 0.16 0f0 0f 0

EPA 0 109 1,800.0 10.60 77 71 32 29

GSA 0 70 1,294.2 13.74 14 20 14 20

HHS 2 1,141 1,268.9 21.00 d d 244g21

HUD 0 16 72.8 7.70 16 100 16 100

Interior 0 34 125.0 5.20 0 0 34 100

Justice N/R N/R N/R N/R N/R N/R N/R N/R

Labor 0 25 176.3 10.70 8h h 8h h 

NASA 0 68 4,553.8 34.20 15i 22 68j 100

NSF 0 1 131.8 69.40 1 100 1 100

OPM 0 7 23.9 7.30 7 100 7 100

SBA 0 5 17.2 38.00 5 100 5 100

SSA 0 26 89.7 14.00 12 46 12k46

Appendix II: Summary of Agency Responses 

to OFPP-Directed Metrics 
Appendix II: Summary of Agency Responses 

to OFPP-Directed Metrics 

Page 18 GAO-04-454 Contract Management 

Dollars in millions 

 Contracts/orders at or above agency specific dollar thresholdsa

 Review by OSDBU 

Review by 

SBSb

Agency 

Number of 

bundled 

contracts 

Total 

number 

Total 

dollars

Percentage of total agency 

procurement dollars for 

FY 2002 Number Percent Number Percent

State 0 0 0 0 0 0 0 0

Transportation 3 260 2,820.7 80.00 3 0m 260 100

Treasury 0 121 1,747.0 57.82 33 27 33 27

VA 11 240 2,811.7 47.14 l l Unknown Unknown

Total 24 

Source: GAO analysis of agency reported OFPP required metrics. 

Legend: 

N/R = not reported, N/A = not applicable 

a DOD = $7M; Energy, GSA, and NASA = $5M; all other agencies = $2M. 

b Small Business Specialist. 

c Cannot be calculated. Review of contracts is not correlated to OFPP threshold requirements. 

d The OSDBU gets involved on a case-by-case basis, when needed. 

e DOD orders off Federal Supply Schedules (FSS) are not required to be reviewed (with a Form 

2579), but may actually be reviewed by a SBS. As a result, this is a “floor” amount and may actually 

be higher because the number excludes all 78 orders off FSS. 

f OSDBU and SBSs only review new contracts, not orders against existing contracts. 

g Contract actions above $100,000 are reviewed by SBSs. 

h Breakdown of contract/orders: 2 were solo source; 9 were unilaterally small business set-asides; 8 

were contracts open market contract awards reviewed by OSDBU and SBS; 4 were orders to large 

business off GSA Schedules; and 2 were orders to small businesses off GSA schedules. 

i

 NASA OSDBU reviews any contract/order over $50M. Fifteen fell into this category. 

j NASA SB specialists review all procurement expected to exceed $100,000. All 68 fit this category. 

k OSDBU serves in the capacity of a SBS. 

l

 VA’s OSDBU does not review contracts and/or purchase orders. It does review the VA Form 2268 

for specific requirements at specific thresholds. OSDBU records reveal that 168 forms were reviewed 

in fiscal year 2002. 

m Actual percentage is 0.15. 

n No SBSs. 
Appendix III: Summary of Contract Bundling 

Rule Changes 

Page 19 GAO-04-454 Contract Management 

The FAR Council and Small Business Administration issued final rules in 

2003 amending the bundling requirements in the FAR and SBA regulations 

(effective October 20, 2003). These amendments implemented 

recommendations in the Office of Management and Budget’s October 2002 

report “Contract Bundling: A Strategy for Increasing Federal Contracting 

Opportunities for Small Business.” The following table summarizes the 

changes and new mandates incorporated in the amendments. 

Table 3: Bundling Regulations, before and after Amendments 

Before amendments After amendments 

Applicability 

An agency was required to conduct market research to determine 

whether bundling was necessary and justified. FAR 7.107(a); 

13 C.F.R. 125.2(d)(3). 

Clarified that it also applies to: (1) multiple award indefinite 

quantity contracts; and 

(2) orders placed against an indefinite quantity contract under: 

—a Federal Supply Schedule contract; or 

—a task/delivery order contract awarded by another agency—

i.e., governmentwide acquisition contract or multi-agency 

contract. FAR 2.101; FAR 7.107(a); 13 C.F.R. 

125.2(d)(1)(iii)(iv). 

Justification of “measurably substantial” benefits 

To justify contract bundling, an agency was required to 

demonstrate “measurably substantial” benefits, which included: 

(1) costs savings, (2) price reduction, (3) quality improvements, 

(4) reduction in acquisition cycle times, (5) better terms and 

condition, or (6) any other benefits. 

Clarified that it also applies to orders. 

Quantification of benefits: 

These benefits were required to be quantified as: (1) 10 percent of 

the contract’s value (including options) if the contract was 

$75 million or less; or (2) 5 percent of the contract’s value 

(including options) or $7.5 million, whichever is greater, if the 

contract was over $75 million. FAR 7.107(b); 13 C.F.R. 

125.2(d)(5)(i). 

Same quantification of benefits analysis, but clarified it also 

applies to orders. FAR 2.101; FAR 7.107(b); 13 C.F.R. 

125.2(d)(1)(iv); 125.2(d)(5)(i). 

Threshold—substantial bundling 

Substantial bundling threshold was defined as a contract worth 

$10 million or more. FAR 7.107(e); 13 C.F.R. 125.2(d)(1)(iii). 

Threshold lowered to: (1) $7 million for the Department of 

Defense; (2) $5 million for the Department of Energy, the 

General Services Administration, and National Aeronautics and 

Space Administration; and (3) $2 million for all other agencies. 

FAR 7.107(e); FAR 7.104(d)(2); 13 C.F.R. 125.2(b)(2)(i)(ii) and 

125.2(d)(1)(iv). 

Appendix III: Summary of Contract Bundling 

Rule Changes 
Appendix III: Summary of Contract Bundling 

Rule Changes 

Page 20 GAO-04-454 Contract Management 

Before amendments After amendments 

Justification—substantial bundling 

To justify “substantial bundling,” agency must, in the 

documentation of that strategy: (1) identify the specific benefits 

anticipated to be derived from bundling; (2) include an assessment 

of the specific impediments to small business participation that 

result from bundling; (3) specify actions designed to maximize 

small business participation as contractors; (4) specify actions 

designed to maximize small business participation as 

subcontractors; and (5) include a specific determination that the 

anticipated benefits of the proposed bundled contract justify its use. 

FAR 7.107(e)(1)-(5); 13 C.F.R. 125.2(d)(7). 

Added a sixth requirement: identify alternative strategies that 

would reduce or minimize the scope of the bundling and the 

rationale for not choosing those alternatives. FAR 7.107(e)(6); 

13 C.F.R. 125.2(d)(7)(E). 

Clarified that these six requirements applied to orders. FAR 

7.107(e). 

New mandates 

Not applicable Agency must coordinate acquisition strategies with agency Small 

Business Specialist (SBS) when the acquisition meets the 

applicable new threshold and is not set aside for small business; 

SBS must then notify agency OSDBU if the strategy involves 

bundling that is unnecessary, unjustified, or not identified as 

bundling by the agency; and 

SBS must identify alternative strategies that would reduce 

bundling. (FAR 7.104(d)(1); 13 C.F.R. 125.2(b)(2)). 

Not applicable Agency OSDBU must: 

conduct annual reviews to assess small business share of 

federal procurements, the adequacy of bundling documentation, 

and actions taken to mitigate the effects; and 

submit assessment to the agency head and SBA Administrator. 

(FAR 19.201(d)(11)(12); 13 C.F.R. 125.2(e)). 

Agency must: 

for any bundling, provide all information about the bundling 

justification, including the acquisition strategy, to the SBA 

procurement center representative 30 days before solicitation 

issuance; and 

for substantial bundling, also provide substantial bundling 

justification documentation to procurement center representative 

and submit all information to agency OSDBU. (FAR 19.202-

1(e)(1)(iii); 13 C.F.R. 125.2(b)(3) and (d)(7)(E)(ii)). 

Source: GAO analysis of regulations. 
Page 21 GAO-04-454 Contract Management 

Appendix IV: Comments from the Office of 

Management and Budget 
Page 22 GAO-04-454 Contract Management 

Contract Management: DOD Needs Measures for Small Business 

Subcontracting Program and Better Data on Foreign Subcontracts. 

GAO-04-381. Washington, D.C.: April 5, 2004.

Small and Disadvantaged Businesses: Most Agency Advocates View 

Their Roles Similarly. GAO-04-451. Washington, D.C.: March 22, 2004. 

Reliability Federal Procurement Data. GAO-04-295R. Washington, D.C.: 

December 30, 2003. 

Small Business Contracting: Concerns About the Administration’s Plan 

to Address Contract Bundling Issues. GAO-03-559T. Washington, D.C.: 

March 18, 2003. 

Small Business: Trends in Federal Procurement in the 1990s. 

GAO-01-119. Washington, D.C.: January 18, 2001. 

Small Business Subcontracting Report Validation Can Be Improved.

GAO-02-166R. Washington, D.C.: December 13, 2001. 

Small Business: Limited Information Available on Contract Bundling’s 

Extent and Effects. GAO/GGD-00-82. Washington, D.C.: March 31, 2000. 

How Selected DOD Consolidation Efforts Affected Small Business 

Opportunities. GAO/NSIAD-83-30. Washington, D.C.: August 12, 1983. 

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