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FEDERAL MARITIME COMMISSION

SERVICE CONTRACT INVENTORY ANALYSIS

FY 2011

As provided in the Office of Management and Budget (OMB) Memorandum on 

November 5, 2010, and December 19, 2011, Service Contract Inventories (SCI), 

(http://www.whitehouse.gov/omb/procurement-service-contract-inventories), agencies 

were tasked to conduct a meaningful analysis of the data in their inventories for purposes 

of determining if contract labor is being used in an appropriate and effective manner and 

if the mix of federal employees and contractors in the agency is effectively balanced. 

The Federal Maritime Commission’s (FMC) contracting staff reviewed each of these 

contracts. The results of this review are summarized below. 

As prescribed in the memorandum, the team reviewed the Product Service Codes (PSCs) 

and Special Interest Functions (SIFs) provided by OMB, as well as the highest dollar 

volume PSCs included in the Federal Procurement Data System – Next Generation 

(FPDS-NG). The following PSCs were reported to OMB as FMC Special Interest 

Functions:

PSC PSC 

Description

Number of 

Contracts 

FY 2011 

for PSC

Total Contracting 

Dollars FY 2011 for 

PSC

D307

Automated 

Information 

Systems 

Services

1 $184,549.00

AGENCY ANALYSIS 

FMC utilized the services of the Bureau of Public Debt for contracting during the first 

and second quarters of FY 2011 for complex procurements or acquisitions above the 

micro-purchase threshold. Seven (7) of the ten (10) Service Contracts on this inventory 

were administered by BPD. 

All service contracts were reviewed. FMC has issued no contracts for personal services, 

and the agency is giving attention, as set forth in FAR 37.114, to avoid contracting for 

functions that are closely associated with inherently governmental functions. The 

following characteristics were adhered to for each of the contracts reviewed:
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i. the agency is not using contractor employees to perform inherently governmental 

functions; 

ii. the agency has specific safeguards and monitoring systems in place to ensure that 

work being performed by contractors has not changed or expanded during 

performance to become an inherently governmental function; 

iii. the agency is not using contractor employees to perform critical functions in such a 

way that could affect the ability of the agency to maintain control of its mission and 

operations; and 

iv. there are sufficient internal agency resources to manage and oversee contracts 

effectively.

One contract represented greater than 1% of the FY 2011 obligations. The remaining 

service contracts represent less than 1% of the fiscal year obligations.

AGENCY FINDINGS 

Due to the lack of procurement staff on site, FMC previously had contracted with BPD 

for procurement services. BPD also had reported procurements to the FPDS-NG System. 

Currently, FMC needs to more consistently identify Product Service Codes on all 

acquisitions handled, as some contracts were identified with miscoding and/or missing 

data elements. 

The FMC will improve the data input process to FPDS-NG for the next submission to 

ensure the complete and accurate retention of contracting data. 

FMC has placed emphasis on awarding contracts to 8(a) firms where feasible and will 

continue to do so. Also, contractors will not be utilized to perform inherently 

governmental functions, but to meet agency needs for skills and services not available 

through staff.