Cancelled by PIC 99-20

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PIC 98-16

Procurement Information Circular


October 21, 1998

CONTRACTOR DATA

 PURPOSE: To assure that necessary contractor-generated data is obtained contractually.

PROBLEM: In recent years only half of the known facilities maintenance expenses were reflected in the NASA Financial and Contractual Status system. This problem has occurred in aerospace projects where facilities maintenance related expense is incidental relative to the overall cost of the project, and the contract does not require the explicit breakout of facilities maintenance data as part of the cost reporting requirement. The cumulative omission of that data is significant, and has necessitated a manual collection of the data. Manual collection is unnecessarily time consuming, and often arrives too late for inclusion in the budget cycle.

BACKGROUND: NASA needs to obtain data related to the performance of its contracts, e.g., to monitor contractor performance, to develop historical data for estimating the cost of follow-on work, to support budget requests, etc. Before Performance-based Contracting (PBC) became common, it was customary to obtain necessary data from the contractors informally. That is, when a need for data was identified that was not already covered under the contract data requirements list, the contractor was simply requested to furnish the data. Under level-of-effort, cost reimbursement contracts, that simple arrangement was convenient and acceptable to both parties. However, under PBC, contractors tend, quite justifiably, to resist requests for effort not explicitly required by the contract because that effort will increase their baselined costs. Therefore, it is necessary to do better advance planning when preparing to award a contract in order to make sure that all data needs are identified at the outset. Some of that data is used by the project/program office, and other data is used by functional or other organizations, such as the data which flows into the NASA Financial Management System from contractor NF 533 submissions. Therefore, it is important that all stakeholders have the opportunity to obtain the data that they need. Furthermore, the Associate Administrator for Procurement is responsible for ensuring that contracts require contractors to provide functional management costs to be used in the NASA accounting system. These principles are already required by NASA policy referenced below.

SUMMARY: Contracting Officers must ensure that all procurement packages are completely staffed to guarantee that all stakeholders have had the opportunity to identify their needs for data. Please follow Center procedures for ensuring complete staffing of procurement packages.

POLICY REFERENCES: NPD 9501.1F, NASA Contractor Financial Management Reporting System; NPG 9501.2C, NASA Contractor Financial Management Reporting; and NPD 8831.1B, Management of Facilities Maintenance.

EFFECTIVE DATE: This PIC is effective as dated and will remain in effect until canceled.

HEADQUARTERS CONTACT: Kenneth A. Sateriale, Code HK, (202) 358-0491, e-mail:

kenneth.sateriale@hq.nasa.gov.

 

R. Scott Thompson

Director, Contract Management Division