In the credit card thread the accuracy of data was mentioned. For years I have been convinced that socio economic programs erupt because of that very issue--inaccurate FPDS data. Part of that reason is because we do not really have a SPOE for contract data. Now I have advocated the following for some time and I would be interested to know what others think. First I would include all sub contract data in the Individual Contract Action Report. And here is the kicker--I would require all contractors to submit a DD294 on every contract awarded wether or not a sub plan was required.My reasoning is that many contracts at significant money are awarded to small businesses who,although not required to submit sub plans, nonetheless do considerable subbing to firms which are SDBs or WBEs etc. By collecting such data we will learn one of two things--first there is no problem for these specific businesses or second we will learn that there is a problem. Such info will also tell us if the most unenforced contract clause Utilization of Small Business, is effective or not. We may also learn that Hubzone firms already meet statutory goals,as well as SDB,WBE, etc. I expect it would also have an impact on the DOC computations for eligible industries. What do you think?

By Charlie Dan on Friday, March 09, 2001 - 10:45 am:

I would disagree with your proposal.

First, this would be a burdensome reporting requirement. The small businesses wouldn't just have to fill out a single form, they would then have to deal with the line of auditors that would eventually come around to review the accuracy of the forms. It would cost the taxpayers an inordinate amount, but more importantly it would discourage even more small businesses from doing business with the Government.

Second, even if it achieved your apparent objective - i.e., identifying enough additional subcontracting with the various socioeconomic categories to meet the mandated "goals" - that would only be temporary. The current goals were established by people who knew what was being achieved using the current reporting processes. They would see that there was really no more $ flowing to the various socioeconomic categories, but that in fact we were just counting $ we had previously not been counting. The real objective for the legislators who issue the goals is to increase the $ going to the SB/SDB/WOB/HUBZone businesses -- not to have the agencies change the way they counted their achievements. If we change the counting procedures, they would simply elevate the goals based on the new counting procedures.

Finally, my strongest objection is that there would be no end to the chain of reporting requirements. Why stop with first-tier subcontractors? We can achieve all our goals if only we flow the reporting requirement down to successively lower and lower tiers of subcontractors or suppliers. By the time we were finished, we'd be requiring DD294s (whatever that is? - I work in a civilian agency) from the guy who refills the soda machines!

By bob antonio on Friday, March 09, 2001 - 01:03 pm:

Thread:

Here is part of the story on P. L. 95-507. In 1972, the Commission on Government Procurement recommended (Recommendation Number A-48) a test of mandatory small business subcontracting. On March 11, 1976, the Office of Federal Procurement Policy initiated this test with the Departments of Defense, Education, Energy, Health and Human Services, the Interior, the General Services Administration, and the National Aeronautics and Space Administration. I started an evaluation of this test in February 1978

Initially, I visited the main contracting offices of the departments and agencies in Washington, D. C. and spoke with contracting staff, small business specialists, and reviewed contracts there. Then I went on a national tour--the Naval Facilities Engineering Command in Norfolk, the Defense General Supply Center outside of Richmond, Marshall Space Flight Center and the Army Missile Command in Huntsville, Rock Island Arsenal in the Quad Cities, the Bureau of Reclamation near Denver, the Space and Missile Systems Organization whose successor is in El Segundo, and the Naval Regional Contracting Office in Long Beach.

The original bill, before it became law, included mandatory subcontracting percentages to be included in solicitations. While I was in Richmond, a congressional staffer called and asked if mandatory percentages worked. I told the individual about all the problems that the contracting activities were having with mandatory percentages in solicitations. This provision was eliminated from the final law. By the time I reached Rock Island in October 1978, I was convinced that actual small business subcontracting data was not being collected and it therefore was underestimated. P. L. 95-507 became law while I was at Rock Island. I remember looking at the Rock Island contracting staff and telling them to be sure they were getting the subcontracting information fully reported.

When I finally briefed the congressional staff, I told them not to pay any attention to the initial year of subcontracting reports after 95-507 was enacted because it would reflect only better reporting and not the effects of the new law. Rather, they should look at the second year's results. As I expected, subcontracting to small business as reflected in reported data increased substantially the first year after enactment and then dropped back in the second year.

As a side note, while I was in Denver I checked to see if a "D. J. Duck" was working there. I had seen these signatures on Bureau documents in Washington and was wondering about his first name. In the hotel in Denver, I turned on Walter Cronkite's evening news and watched a news piece from an audit that was conducted in Washington. The auditing arm of Congress had just tested the Department of Housing and Urban Development's (HUD) accounting system and planted the names of Mickey and Minnie Mouse in the payroll system to see if HUD would pay them. Well, HUD wrote pay checks to Minnie and Mickey Mouse. After the piece, Walter Cronkite looked into the camera and noted that at the Bureau of Reclamation in Denver, Colorado, Donald J. Duck was a high ranking federal official and he gets paid too. Yeah, "D. J. Duck" was Donald J. Duck.

In Washington, the accuracy of information is very important.

By curious on Friday, March 09, 2001 - 02:45 pm:

Yes - I can assure you Donald Duck was a real person with Reclamation at the time!

There apparently is a Rapid Implementation Team (RIT) that has been established to improve FPDS in light of technology advancements, so that it can be accessed real-time, work better with agency feeder systems, etc.

I think the DOD Change Management Center may be leading this effort. Is anyone on that team or know where things stand? THey had a kick-off meeting in July 2000.

By C Mercy on Friday, March 09, 2001 - 03:55 pm:

CD
OK I asked. Now let me see if I can't further explain. In your first objection you mention auditors. In 23 years I have never seen an auditor examine a sub contracting report. (DD294). Its impact on taxpayers would be minimal...and if accurate first tier sub reporting were required and,like DOD, when goals were met agencies were not required to include the SDB or Hubzone PEA we would automatically save the taxpayers some money. The estimated cost of the report is $65. --hardly a number that would discourage a successful contractor.
Second The objective is not to show wether a goal is met or unmet,rather it is to accurately count Federal dollars and their impact in the various business communities.. I would bet a weeks pay that the 3% Veterans Small Business goals are already met...without the legislation!!!
If such data were accurate we might not have to fix the things that ain't broke and we could focus on those matters that actually were.
Third there is already a flow down reporting requirement. What's the dif?
I believe that if Congress knew more of where the Federal dollar actually wound up there would be some chance of not having to create new programs---or better- perhaps we could eliminate some of these programs altogether (that extra twenty per cent we add to Hubzone-SDB offers would be nice).

By Charlie Dan on Friday, March 09, 2001 - 04:58 pm:

Unfortunately, I'm one of those who HAS been audited for SB/SDB subcontracting info (when I was working for a contractor). The auditors were going full-depth into our subcontract reports, looking for back-up information, etc., etc. The audits went on for the better part of a year. I admit I'm sensitive.

The dif is that you would require the reports from small businesses. I'm not sure who came up with the $65 estimate, but I would bet that number would not be adequate for the small business that has never had to accumulate any of this information before. Much less report it. Right now, why would a small business even maintain a database of its subcontractors' size status? This is something that is not even considered by a small business that is focused on commercial work. That is my point - we keep making it harder and harder to do business with the federal government, by adding more and more requirements that businesses don't have to face anywhere else. The large businesses accept this, establish entirely separate units that accommodate the bureaucratic requirements. But small businesses can't afford this.

I finally understand that what you're really looking for is relief from the price adjustment. (For the life of me, I couldn't figure out what PEA stood for. I've been away from DOD for too long. The rest of the Govt uses acronyms, but DOD has taken it to an entirely new language.)

The price adjustment provisions are the problem, not the reporting. Again, my belief is that the thresholds for applying price adjustment requirements would be adjusted upward by those who set the original thresholds. They are looking for INCREASES in utilization of the various forms of businesses, not just better accounting of the current situation.

Why don't we agree to disagree on this one?

By bob antonio on Friday, March 09, 2001 - 05:16 pm:

curious:

Donald Duck was then a supergrade government employee. I seem to remember he was an associate something or other. That is the equivalent of an SES position now.

I had a good laugh when I saw the TV article.

By bob antonio on Friday, March 09, 2001 - 05:21 pm:

curious

If they would change the 279 and 281 into a web-based "form" document, the data could be placed into a system in that manner. The information could be collected on a database and then be offered. The one problem I can see is that there may be bottlenecks due to the volume of traffic. However, they should be able to think of something.

By curious on Friday, March 09, 2001 - 05:31 pm:

With the technology available today, I'm confident that reporting to FPDS can be done in a much more efficient and accurate manner. It is just a big effort up front to develop the system criteria and pull it all together.

I like the idea of a web-based submission process!

Everyone, have a great weekend!

By formerfed on Monday, March 12, 2001 - 08:26 am:

Bob,

A web-based system seems like a good solution. Another more promising approach (or at least a complimenting approach to web-based) is to fully utilize existing capabilities of COTS packages. Most COTS systems provide for capturing FPDS data as awards are prepared. Between 60% and 80% of the required data elements are system generated, so the Contract Specialist just needs to complete the missing elements. The problem is too many barriers exist to take full advantage right now.

By C Mercy on Monday, March 12, 2001 - 10:07 am:

CD
OK we will agree to disagree. One of my reasons for the initial suggestion concerns the "New Urban Agenda Act" (S23). This legislation has been working its way for quite awhile now and it may just pass. I have read it and although it seeks to assist businesses in certain areas it is not small business friendly. If however we could demonstrate that there was no actual need for such a program, because we did possess accurate data, it would ultimately benefit small businesses. By the way this bill seeks to award fifteen per cent of prime contract dollars to firms located in three categories of "empowerment zones" But again there is no mention of small businesses.

By Kennedy How on Monday, March 12, 2001 - 12:18 pm:

The first thing that occurred to me when I started reading this thread last week was that this whole issue is a Catch-22 to all involved. Nothing that has been written since the first couple of posts has changed that.

The biggest problem is that neither side has the data available to prove or refute their position. The only thing that anybody can point to is "well, I THINK it has to be.....", or, "We BELIEVE it should only cost....". None of these statements are going to fly with whatever special interest group/congressperson who's interest this issue lies. The only way to answer something like that is "we're going to have to go out and get the data". The reply "We're not going to get the data because we believe it's too onerous on industry." isn't going to get you anywhere.

We spend a lot of time at the end of fiscal years reprogramming our automated Individual Contract Action Report (ICAR, DD Form 350). Every year, they've added some oddball requirement (Hubzone? Historically Black College?) because somebody decide that we needed statistics in those areas.

If the Government stopped spending so much time on social engineering in acquisition, we wouldn't have to gather all of this data that "burdens the small business". Because it allegedly costs them money to report, they are actually hurting themselves, so say some of you. But we'll never really know, because most of the benefits are hidden, because we don't require the reporting, and any evidence to the participation of small business in the federal procurement arena is anecdotal at best. That usually doesn't fly when the congressperson in charge of the Small Business committee asks about it.

Kennedy

By formerfed on Monday, March 12, 2001 - 01:11 pm:

Kennedy,

Interesting point. That got me thinking - I wonder how much time, effort, and expense goes into the overall FPDS reporting system? Also, how much benefit results? Could the same goals get accomplished through a sampling technique? (except the old "how many dollars got awarded to such and such firm in my district?"). Wonder how much everything changes year to year, with fluxuations in budget excluded? Maybe a cost/benefit analysis of the overall reporting process...

By C Mercy on Monday, March 12, 2001 - 03:56 pm:

Kennedy
Yup you are right they are oddball requirements but how would we report to Congress what we accomplished in relation to the statutory mandates without using FPDS? In FY00 I think the requirement was 1.5 % of prime and sub dollars to be awarded to Hubzone firms. But since we do not capture sub dollars in FPDS ,only prime Hubzone dollars show up...which is exactly my point.Now I will tell you something I do know for a fact...in my agency we did almost 5% in HZ prime contracts during the initial year. And there was only one action on a total HZ set aside and no HZ won on the basis of the PEP. We had been doing business with many of these firms all along. Now if that were true for 3% of all prime contracts awarded by the federal government combined with sub data the statutory goals could have been shown to have been achieved without the statute.

FF
Almost regardless of cost I think the FPDS could be improved in ways that both agencies and Congress could well benefit from..and could lead to constructive ,or better, even necessary social engineering. On the other hand, spending 200 billion in a ten trillion dollar economy who cares if a little social engineering is required?

By bob antonio on Tuesday, March 13, 2001 - 12:12 pm:

formerfed:

Whatever system they use, it should be the simplest they can identify. I believe the socioeconomic programs are ripe for a thorough review. We have SCORE, SBDCs, WOBCs, etc. We have veterans' programs, womens' programs, minority programs, small business porgrams, and geographical programs.

In developing programs, we need to ask three questions.

First, what do we want to do?

Second, how will we do it?

Third, how will we know if we did it?

If we cannot answer all three questions from the beginning, we should not create the program. This thread is discussing the third question. When many programs are created, I bet questions two and three are ignored many times.