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: firstname.lastname@example.org.
William P. McNally
Assistant Administrator for Procurement