As a result, OFPP Administrator Joe Jordan has issued his
third wave of these
memos earlier last week, where he outlined specific targets for PPIRS usage
and outlining other initiatives to help with the inconsistent documenting of
contractor performance.
The new memo outlines stepped targeting and goals, based on
the level of agency inconsistency, so that better performing agencies have
higher goals than agencies performing poorly. This certainly makes sense, given
that not all agencies are performing at the same level so it would be
nonsensical to expect all agencies to perform and abide by the regulations. All
agencies are expected to be at 100% reporting by 2015.
Although the memo discusses targets and the actions taken to
date, they have had little impact in improving past performance data.
According to the memo:
...OFPP
has developed a MAX site that includes metrics from the standard
PPIRS
Compliance Metric Report and allows for agencies to record their baseline and
target information at https://max.omb.gov/community/x/JoNKJQ. A summary of the
reports and tools available for use in this exercise are listed in Attachment
1, and the site will also include best practices gathered from earlier OFPP-led
Acquisition Status (AcqStat) meetings...
What ever happened to those AcqStat meetings, where senior
procurement officials where so supposed to review data and make strategic
decisions to improve performance outcomes? According to Freedom of Information
Act requests obtained by FierceGovernment, not much. Other than sign in sheets,
the lack of transparency was alarming, if not expected.
I often advocate for fewer regulations and oversight, and
there is absolutely no need to create new ones to address this issue.
Nonetheless, improvements in this area can go a long way to help transform how
contractors are selected for awards, and dramatically improve outcomes.
However, it is Page 3 of the memo that is most important to
help understand the current failures, and the recommended actions that should
be properly implemented that would have a dramatic effect:
...In
support of this effort, agency CAOs and SPEs must also take the following steps
to ensure that relevant performance and integrity material is reported appropriately:
1.
Communicate to the workforce the importance of using past performance information,
including the need to have frequent communication with contractors - such as
holding interim evaluations to address performance issues, and share the
agency’s plans for achieving success in this area;
2. Hold staff accountable for
improving the quality and quantity of the information; [emphasis added]
3.
Motivate employees to take action to fulfill this responsibility and use innovative
practices to meet this requirement; and
4.
Consider recognizing acquisition professionals who contribute to improvements
in this area, such as through the annual CAO Council Acquisition
Excellence
Awards…
Although I believe #3 above is redundant, certainly understanding
the need of why this information is needed, and training the workforce on how
to properly perform these reviews, are critical for these new goals to be met.
We can of course forget the opportunities for training and
educating the workforce should the ridiculous meat-cleaver of Sequestration go
into full effect, although those opportunities are already starting to
disappear fast.
Nonetheless, what the memo fails to address is why the
information is not being entered into PPIRS to begin with, and also why
contractor oversight is currently so lax. It is a startling abrogation of ones
duties to those responsible with being stewards of taxpayers money, and one
that needs corrective actions through enforcement and proper program
management.
For starters, some contracting officers that I have spoken
to have taken the same attitude towards muted debriefs and the lack of
transparency for reporting contractors demonstrating poor performance; that is
to say "better safe than sorry, no thanks."
Because contractors have the right to appeal poor reviews,
(rightly I might add, to defend against over-zealous officials abusing their
power) some procurement officials just don't want to deal with the hassle.
Although proper documentation should exist to demonstrate repeated poor
performance, many argue the battles are not worth it.
Exacerbating the issue are highly performing procurement
officials who get no top-cover from leadership due to the too-cozy
relationships they have with contractors. The attitude is one of frustration,
indifference, or simply ignorance.
Further, why should they? As a senior level procurement
official told me while discussing the issue of the overall lack of
accountability in the procurement process,
"People get paid every two weeks, if they perform or
not."
I think it is safe to say we need to change this attitude.
Past performance, especially for services, should be one of the most important
evaluation criteria in selecting a contractor for award. However, the
incomplete or missing data, combined with allowing contractors to submit their
own evaluations from favored customers, often does not allow for
differentiation and drives evaluations in areas that often let irresponsible contractors
get way with murder because they offer ridiculously low-prices to win work in this
era of institutionalizing "buying in."
In addition, what is the point of requiring in contracts
status reports, weekly deliverables, monthly reports and deliverables, etc. in
the areas of program management if they are not going to be used to address the
issue of performance? What is the point of doing this? What contract does not
already contain the interim status reviews being recommended?
Other than creating pretty pie charts, graphics, and killing
trees, this vast amount of performance information is not being used properly,
nor does it improve outcomes. I believe the lack of project management
capability of the acquisition workforce is obviously an issue, but the one-two
combination of poor accountability adds fuel to the fire.
Doing more with less is the foreseeable future in how we
manage government contracts, but until enforcement and education really happen,
we are epitomizing the definition of madness.
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