11-03
Procurement
Information Circular
PURPOSE: The purpose of this PIC is to set forth the
minimum requirements for Center Data Quality Plans (DQPs). The plans must cover contract and federal
financial assistance awards (i.e., grants and cooperative agreements) for those
centers that process both. The DQP encompasses criteria for the Federal
Procurement Data System-Next Generation (FPDS-NG), USASpending.gov, Contractor
Performance Assessment Reporting System (CPARS), Federal Awardee Performance
Integrity and Information System (FAPIIS), Federal Funding Accountability and
Transparency Act Subaward Reporting System (FSRS) and the Electronic
Subcontracting Reporting System (eSRS).
REFERENCE: NASA FAR Supplement 1804.6 – Contract
Reporting, 1804.604(c)(ii)(I); PIC 10-13 dated Sep.
23, 2010, and GIC 11-01 dated Jan. 24, 2011, both entitled Implementation of
the Federal Funding Accountability and Transparency Act (FFATA) of 2006.
BACKGROUND:
The purpose of the DQP is to outline adequate processes, procedures and
internal controls to ensure integrity of data available to the public. The existing Center DQPs, developed and
approved in 2008, discuss the broader aspects of how data quality, both at data
entry and after, is validated and verified.
Since 2008, Center unique tools, checklists, targeted training and very
specific step by step procedures were developed and adopted that now must be
memorialized in the Center DQP.
OMB’s Open Government Directive, M-10-06, dated Dec.
8, 2009, requires agencies to be accountable for the quality of Federal
spending information that is publically disseminated through USASpending.gov
and other similar websites, and to work to improve the quality and integrity of
that information. The Office of
Management and Budget’s memo dated Feb. 8, 2010, issued guidance agencies used
in developing their agency level general DQPs.
NASA’s May 14, 2010, DQP describes how NASA compiles, reviews, and
monitors the quality of data and how control processes are applied to the information
NASA inputs and submits to FPDS-NG and USASpending.gov.
FAR Part 4.604 requires agencies’ Chief Acquisition
Officers to certify annually that FPDS-NG records are complete and
accurate. The Office of Federal
Procurement Policy (OFPP) also requires agencies to take additional steps
beginning in FY11 to improve the quality of “other acquisition-related” data
and information related to contractor’s past performance, business ethics,
executive compensation and subcontracting.
Examples of other acquisition-related data and information are past
performance assessments in the CPARS, Contracting and Grant Officer input into
the CPARS/FAPIIS module, Contracting and Grant Officer monitoring of contractor
and recipient compliance with subaward and executive
compensation reporting in the FSRS, and Contracting Officer (CO) verification
of contractor submitted reports in the Electronic Subcontracting Reporting
System eSRS.
GUIDANCE: Each Center/NSSC must reevaluate its DQP
annually to ensure that it continues to meet the minimum requirements. The NFS 1804.604(c)(ii)(I)
includes a hyperlink to the DQP template.
Part
1. Center Data Quality Plans – Input and
validation of data entered in CMM/PRISM and the FPDS-NG
The Center DQPs shall be modified specifically to
include a detailed process flow or step by step procedure used to ensure FPDS
data accuracy at data entry and after.
Items (3) and (4) of the DQP template may be used to document this
process or an attachment may be added to the plan. At a minimum the FPDS-NG process flow detail
shall include:
a. The CO is ultimately responsible for data
validation in CMM/PRISM and FPDS-NG.
b. For contracts, document how you ensure compliance
with FAR to have actions in FPDS-NG within three business days of award.
c. For contracts/grants/cooperative agreements,
document how prior to launching in FPDS-NG, you ensure the data is complete and
accurate. (Refer to Enclosure 1 for
grants/cooperative agreements).
Centers who utilize data quality teams and data input templates to
analyze data accuracy need to document the process flow steps. Address how you rectify discrepancies and
whether any documentation is produced as a result of error corrections (e.g., a
copy of the data input sheet and/or finalized CAR in FPDS-NG is included in the
contract file.).
d. For contracts, other than conducting the
semiannual statistical random sample of FPDS-NG contract data, document the
process used after the fact to validate FPDS-NG data accuracy (e.g., use of
EPDW scorecard reports that show mismatches between data in PRISM/SAP/FPDS-NG;
EPDW data discrepancy reports by certain data elements) and what process is
used to correct any errors found.
e. For grants/cooperative agreements, document how
data accuracy will be verified and validated through periodic random samples of
grant action records in FPDS-NG against the grant files. (Refer to Enclosure1 for
grants/cooperative agreements).
Other than periodic random samples, document other tools used to validate
FPDS-NG data accuracy and the process used to correct errors when found. Examples of other tools could be use of
Center specific reports, periodic second set of eyes reviews, use of
Headquarters notifications that result in data corrections, use of the
Electronic Procurement Data Warehouse (EPDW) scorecard reports that show
mismatches between data in PRISM/SAP/FPDS-NG, and use of EPDW data discrepancy
reports by certain data elements.
f. For contracts/grants/cooperative agreements, use
the self-assessment report to document specific data quality activities
undertaken since the last report and identify any success or challenges related
to such activity.
g. NFS
1804.604(c)(ii) states that the HQ Office of Procurement (OP) will randomly
select contract actions (excluding grants/cooperative agreements) and provide a
list to each Center on or about April 15th and October 15th
each year. Centers will use these
actions to conduct a verification and validation twice a year.
Part
2. Center Data Quality Plans - Other
Acquisition-Related Data beyond FPDS-NG.
Regarding the quality of “other acquisition-related”
data and information, the Center DQPs shall be modified to include policies,
procedures, and internal controls that address reviews of qualitative data
(e.g., CPARS and FAPIIS) and quantitative data (e.g., USASpending,
eSRS, FSRS). Refer to Enclosure 2, Checklist
for Acquisition Related Data Systems, designed to assist contract and grant
officers with the requirements of these various data systems. At a minimum, the DQPs shall include:
a. a process for ensuring that COs/Grant Officers
verify contractor and recipient/sub-recipient reporting in FSRS of
contract/grant sub-award data and executive compensation; and
b.
a process for ensuring that COs/Grant Officers verify that they are inputting
the required information into FAPIIS.
c. The HQ OP will run a monthly FPDS report on
Terminations for Default or Cause and then verify whether the CO input this
information in FAPIIS. HQ will notify
the Center point of contact and require a response once FAPIIS is updated. The Center DQPs shall include a process for
ensuring timely FAPIIS data input and response to HQ, when necessary.
d.
The Center DQPs shall also include a process for verifying other quantitative
(e.g., is the data in FAPIIS) and qualitative (e.g., is the information clear
and provide valuable understanding for the intended recipients) FAPIIS
information regarding:
-
CO Determination of Defective Cost or Pricing Data or Determination of Non-Responsibility,
-
Grant Officer Terminations for Material Failure to Comply or Recipient Not
Qualified.
e. Use the self-assessment report to document
specific activity related to monitoring and improving procurement data quality
since the last report in systems beyond FPDS-NG: in CPARS (e.g., results of assessments
related to past performance reporting compliance and quality of the past
performance write-up), FAPIIS, eSRS, and FSRS data systems (e.g., contractors’
compliance with reporting requirements such as subaward
reporting required by FFATA).
f. Discuss the process that exists between Center
small business specialist and COs to ensure contractors with subcontracting
plans are submitting Individual Subcontracting Reports (ISRs), as well as the
review, acceptance or rejection of ISRs in eSRS.
g. Discuss use of Past Performance Information
Retrieval System (PPIRS) and CPARS compliance tracking tool to identify if
evaluations have been completed on eligible contracts.
EFFECTIVE
DATE: This PIC is effective as dated and shall remain in
effect until cancelled or superseded.
HEADQUARTERS
CONTACT:
Kerrie O’Hagan, Analysis Division (202)358-0609, email: kerrie.ohagan@nasa.gov.
/s/
William
P. McNally
Assistant
Administrator for Procurement
Enclosures:
DISTRIBUTION:
PIC List