ML12005A065

2010 Procurement Data Submission Certification to the FPDS-NG

ML12005A065
Person / Time
Issue date:	12/29/2010
From:	Greene K Office of Administration
To:
References
FOIA/PA-2012-0046
Download: ML12005A065 (8)

Text

Agency FPDS Data Quality Report Agency Name: US Nuclear Regulatory Commission Fiscal Year of FPDS Data: 2010 Agency Data Number of Contracting Offices Providing Data to FPDS: 5 Total Procurement Obligations for this fiscal year- $199,958,766.82 Part I - Data Quality Certification Certification Statement

[ certify that 82% of all reportable contract actions awarded during FY 2010 for my agency have been entered into FPDS as fully and accurately as possible as of the date of my signature.

[Agencies unable to certify entry of 100% of their reportable contract actions must discuss the reasons for this and their plans to. remedy this situation under the following section of this Part.]

Explanation of Data Missing from Certiffcation The 18% of actions that are not certified will be corrected in FPDS. The corrections should be completed by the end of the second quarter of FY 2011. The corrections witl be checked for accuracy to ensure 100% certification of data at that time.

Part 11 - Assuring Data Input Accuracy Agencies' efforts to assure the input of high quality procurement data typically fall into three broad groups of activities. The first two groups consist of activities intended to: (1) assure that accountability for data accuracy is clearly defined and property assigned, and (2) implement quality controls over data input. The third group consists of other measures that agencies may take to monitor and improve their data quality on a routine basis. Please discuss your agency's activities to assure data input accuracy according to the following outline along wdth any other points you want to include.

Accountability for Data Accuracy

1. Addmess whether or not data quality was included as a critical element, included but not as a critical element, or not addressed in the performance evaluations of contract specialists, contracting officers, heads of contracting activities, senior procurement executives, and chief acquisition officers.

Data quafliy was not included as an element in performance evaluations of contracting staff.

2. Describe any other ways in which personnel in the agency and its subordinate components were held accountable for ensuring FPDS data accuracy.

Data is reviewed by the cognizant Contracting Officer prior to approval and award. This helps to ensure accuracy by providing a second review of the data entered by the Contract Specialist.

3. Discuss any barriers or challenges that your agency faced in mnplementiug accountability for data accuracy throughout the agency, and any steps that the agency has taken, or is planning to take, in FY 2010 and FY 2011 to improve such accountability.

In FY 2010, the Division of Contracts (DC) provided training classes on specific data values in FPDS-NG to improve data quality. These classes wil continue in FY 2011, and DC wl be utilizing contractors to assist with data dean up to improve data quality in order to assist wdh migration of data to acquisiton system that wil be implemented by October 1, 2012_

Controls over Data In"ut

1. Provide the percent of the agency's FPDS contrac action reports (CARs) entered directly from each contract writing system(s) used by the agency, the percent entered directly into FPDS through the web portal, and the percent entered by any other methods during this fiscal year-

a. Contract Writing System(s) (Identify name and version)

Distributed Solutons, Inc. Automated Acquisition Management Solution (AAMS) 100%

Version 7.4

b. Web Portal (On-line login)

c. Other Total 100%

If applicable, please describe any Other' method(s) used:

2. Identify the positions (e.g., contracting officer, contract specialist, clerk, etc.) of the individuals that entered the CARs into FPDS, by checking all that apply.

a-Federal employee - contracting officer X

b. Federal employee - contracting specialist X

c. Federal employee - data entry clerk

d. Federal employee - other. Please specify

e. Contractor - program managerlkey personnel

f. Contractor - data entry clerk

g. Contractor - other. Please specify

3. Identify the positions (e.g., contracting officer, contract specialist, clerk, etc-) of the individuals that approved the CARs entered into FPDS, by checking all that apply.

a. Federal employee - contrading officer X

b. Federal employee - contracting specialist

c. Federal employee - data entry clerk

d. Federal employee - offer. Please specify

e. Contractor - program manager/key personnel

f. Contractor - data entry clerk

g. Contractor - other. Please specify 2

i.

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4. Discuss the type and frequency of procurement and FPDS training provided to personnel who enter CARs into FPDS.

Afl DC personnel received targeted training on FPDS on several occasions in FY2Of1.

This training concentrated on problem areas discovered during the FY2009 FPDS data validation review. In addition, the NRC "cheat sheet', which was provided to staff in FY2009 to assist with definition of each required field, was updated and distributed several times over the course of the year. It is also posted on an internal website for easy reference at any time. The FPDS user manual was also provided for more detailed item research.

5. Identify whether al data elements in all CARs had to pass the FPDS edits before the corresponding awards could be issued by the agency's contract writing system. If only some data elements or some CARs were subject to the FPDS edits, identify them.

The contract writing system relies on the validations in the FPDS system. There are no built in validations in the contract writng system. In FY11 NRC is scheduled to award a contract for a new contract writng system with required pre-award validation.

6. Discuss any other procedures, e.g., internal controls, used by the agency to ensure that data entered into contract writing systems and FPDS were correct when entered.

Data is reviewed by the cognizant Contracting Officer prior to approval and award. This helps to ensure accuracy by providing a second review of the data entered by the Contract Specialist.

7. Discuss any barriers or challenges that your agency faced in establishing effective controls over the accuracy of data going into FPDS, and any steps that the agency is planning to take in subsequent fiscal years to establish such controls.

A new contract writing system with pre-award validation checks wil be implemented in FY12/13.

In addition a proposed multi-tier review system for contract actions is currently being reviewed by both DC management and the Office of General Counsel's management. These reviews would provide even more reviews of the data being entered into FPDS, reducing the likelfhood that any mistakes could become Finalized In the system.

Other Data Quality Assurance Procedures Discuss any other procedures used by the agency on a routine basis during the year to review the accuracy of its procurement data in contract writing systems and/or FPDS and to correct any errors found. Discuss separatety any other such procedures that the agency is planning to implement in subsequent fiscal years. Examples of such procedures might include:

Contract Specialists and Contracting Officers were required to independently review the applicable FPDS data for each acquisiffon action (awards and modifications) and certify that the data was accurate and complete. The Contracting Officers reviewed, prior to an action being awarded, all FPDS data collected in the NRC contract wriling system. AM Division of Contracts (DC) staff was tasked with reviewing 100% of their own FPDS data.

In addition, periodic anomaly reports were run from FPDS throughout the fiscal year, so that contract specialists and contracting officers had the opportunity to review data for accuracy and make necessary corrections.

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Part Il - Measuring and Reporting Data Accuracy There are four factors that affect the quality of the data accuracy results reported on the Attachment to this Exhibit. The first two deal with the independence and qualification of the persons who review the FPDS records and contract fifes. The second two deal with the scope and adequacy of the review process itseW. Please discuss your agency's policies and procedures for measuring and reporting the accuracy of your FPDS data according to the following outline along with any other points you want to include.

Independence of Reviewers

1. Discuss whether the persons who reviewed and validated the FPDS data were government employees, contractors, or a combination thereof.

The review and validation of NRC's FPDS data was conducted by contractor personnel Review of the contactor's findings was done by government employees.

2. Were all sampled contract action reports (CARs) validated against the associated contract files by individuals other than the persons who entered the contract data for those CARs and the contracting alilcers who awarded those contracts? If not, explain why not Also, discuss additional steps, if any, you have taken beyond those required by the OFPP guidance that address the independence issue.

Yes.

3-Discuss any changes that the agency plans to make with respect to this issue in subsequent fiscal years.

As a follow on actfviy, the conftctor who conducted the reviews of the FY20O1 data is writng Standard Operating FRocedures (SOPs) for staff to follow when entering data in AAMS, which ultimately flows into FPDS. Additionally, the contractor wil have staff available onsde to provide desk-side support to contract specialists as quesbos regarding proper data entry procedures arise.

Quaf fications of Reviewers

1. Describe the qualifications reviewers were required to have with respect to contracting experience and FPDS.

All of the reviewers have hands on experience conducting this same review at other federal government agencies.

2. Describe any special training on Federal procurement rules and procedures that was provided to the revie None.

3. Describe any special training on FPDS that was provided to the reviewers.

None.

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4. Discuss any changes that the agency plans to make with respect to this issue in subsequent fiscal years.

None.

Scope of Review

1. Describe whether the contract action report poplation from which the sample was selected included:

a. All transaction types (e.g., modifications, delivery orders, etc.);

b. All components of the agency that submit contract action reports to FPDS;

c. Data from all four quarters of the fiscal year; and

d. Transactions funded from non-appropriated funds. [NOTE: Transactions from non-appropriated funds should not be reported to FPDS unless approved by the GSA FPDS Program Office.]

The contract action population from which the sample was selected did include all confrac types; all components of the agency that submit actions to FPDS, and data frnm all four quarters of the fiscal year.

2. Describe whether your agency validated at least all data elements identified in the OFPP guidance. If it did not, discuss why.

AM of the data elements described in the OFPP guidance were reviewed

3. Identify any additional data elements reviewed beyond those requested in OFPP guidance.

N/A

4. Describe whether the agency reviewed all the records identified in the sample.

AM of the records idenht*ed in the sample were reviewed.

5. Discuss any changes that the agency plans to make wih respect to this issue in subsequent fiscal years.

Going forward, and assuming that funds are available NRC wig continue to use contractor staff to perform this review. Their review is objective, and the contractor has tools that can be used to perbrm the reviews more quickly than if they were performed in-house by NRC staff In-house government employee resources are not sufficient to perform the same level of review as the contractor can provide.

Adequacy of Review

1. Describe the sample design and methodology used to select the contr action reports for the sample. If the agency did not select a random sample of contract action reports, describe the sample selection method that was used and justify how the sample is providing useful information about the accuracy of data elements.

A random sample was taken from afl contract action reports.

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2. Identify whether the agency selected a sufficiently large sample to comply with the statistical precision standard requested by OFPP (i-e., a 95% confIdence Level of -5 percentage points around the accuracy rate), and provide the 95% confidence interval for the overall accuracy rate and the data element accuracy rates. If the requested standard was not achieved, explain why the current sampLe was used and why the standard could not be met NRC selected a statistically valid sample at the data elementifeld level for each data element required to be audited The statstical sampling was conducted in a random manner and does adhere to the required precision standard of 95% with confidence level of +/-Z 5% rather than 5% The confidence interval is provided for in the data element accumacy rate and m the overall accuracy rate.

3. Did your agency pull the sample and conduct its review at the overall agency level or at the component level? If at the component level, indicate the number of components that conducted reviews, whether the SPEs (or equivalent) at those components reported the confidence levels of their samples to you, and what those confidence levels were.

The sample and review were conducted at the overall agency level.

4. Identify whether the reviewers compared the data elements in FPDS to the information in the contract file. If not, describe how they validated the data elements.

Reviewers puffed the contract fles and compared the data in the fiMe for the specifed record to what is in FPDS.

5. Identify whether the review included additional steps to validate the FPDS data beyond a comparison to the contract file (e.g., logic tests of relationships among related data elements, anomaly reports, etc.). Describe the additional methods used.

No additonal methods were used for the FY 2010 review.

6. Discuss any changes that the agency plans to make with respect to this issue in subsequent fiscal years.

As mentioned in the previous section, assuming that funds are avaitlable, NRC will be wxking with the contractor to develop a more proactive approach to these reviews in FY201 1.

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Other Acivities to Validate Data Please summarize any other activities pefred by the agency to measure and report the accuracy of its FPDS data that aren't included in the discussion of the preceding four factor.

Reauired Sianature

0. hawNEnc SENIORPROCUREMENT EXECUTIVE NAME (Printed)

SENIOR PROCUREMENT EXECLIVE SIGNATURE 141 w i1,* a,,,,*,=IB UR I r 7

L Agency name: Nuclear Regulatory Commission Percent of Total Procurement Spend covered by sample:

4M Accuracy Computation for Key Data Elements Fiscal Year of FPDS Data: f=IO Data Element CAR Accuracy Rate: =

Systemic Causes of Invalid Data Data Element Name 2A Date Signed 2C Completion Date 2D Eat, Ultimate Completion Date 2E Last Date to Order 3A Base and All Option Value 3B Base and Exercised Optlon-Value 3C Action Obligation 4C Funding Agency ID 6A Type of Contract 6F Performance Based Service Acquisition 6M Description of Requirement BA Product/ServIce Code 8G Principal NAICS code 9A DUNS No 9H Place of Manufacture 9K Place of Performance ZIP Code (+4)

IOA Extent Competed IOC Reason Not Competed IOD Number of Offers Received***

ION Type of Set Aside lOR Statutory Exception to Fair Opportunity IIA CO's Business Size Selection 118 Subcontract Plan.

12A IDV Type 128 Award Type Total Records Sampled (Column A)

No. of Records Reviewed 1351 1282 1267 108 1351 1282 1282 1351 657 657 1351 657 362 364 467 636 399 406 657 655 281 362 341 30 627 18183 (Column B)

No. of Correct Records 1244 994 928 66 1150 810 1201 1293 602 542 1225 598 185 350 377 437 246 245 492 580 94 321 245 29 607 14861 Column B/

Column A as %)

Accuracy Rate 92%

78%

73%

61%

85%

63%

94%

96%

92%

82%

91%

91%

51%

96%

81%

69%

62%

60%

75%

89%

33%

89%

72%

97%

97%

82%

(Check all that apply) -

User x

x X

X X

X X

x X

X X

x x

X X

x x

X x

X X

X X

X X

FPDS Other x

X X

X X

1 x

1p X

X

• • • This data element must be validated beginning with FY 2010 data, but Is not required to be validated for the FY 2009 data.

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