Ensuring the Accuracy and Integrity of Publicly Accessible Procurement Data Procurement All Hands July 2, 2013
Pre-Award Public Data: It Begins With Pre-award public data begins with your NASA Acquisition and Internet Service (NAIS) Electronic Posting System (EPS) synopsis and subsequent document upload postings (i.e., draft and final solicitations, Q&A). Once posted, this data is made available on NASA’s NAIS Business Opportunities site. Note: There is no electronic monitoring /review of your uploaded data. It is up to the CO to ensure documents are suitable for uploading. To ensure data accuracy and integrity, and reduce posting errors, the Division is evaluating its posting processes and associated policies.
Before You Upload…. The CO must ensure uploaded documents contain no proprietary or sensitive data. The Contractor’s document(s) may be marked with a proprietary legend, or not. NOTE: Lack of a legend doesn’t necessarily mean there is no proprietary data involved. The CO should also ensure any in-house information is successfully removed from your uploads (i.e., accept all changes and remove any comments). Do not assume files you receive from others (both cost and technical) are ready for uploading. If possible, verify with the author of the file if the file contains any proprietary data or not. Use another set of eyes if possible; ask someone else to review the file(s). Prior to posting any contractor historical data, ensure you have the Contractor’s consent (i.e., labor rates, labor categories, other 533 reported data).
Sensitive But Unclassified (SBU) Information Sensitive But Unclassified (SBU) Controlled Information/Material – Unclassified information or material determined to have special protection requirements to preclude unauthorized disclosure to avoid compromises, risks to facilities, projects or programs, threat to the security and/or safety of the source of information, or to meet access restrictions established by laws, directives, or regulations; examples: ITAR- International Traffic in Arms Regulations – Export-controlled Item* EAR- Export Administration Regulations – Export-controlled Item* Privacy Act Proprietary - Internally generated data or documents that contain technical or other types of information owned and controlled by a firm to safeguard its competitive edge. Scientific and Technical Information (STI) Source Selection and Bid and Proposal Information Inventions (NPR 1600.1, CHAPTER 10) *Export-controlled: items (i.e., technology, commodities, software) subject to the EAR (15 CFR Parts 730-774) or the ITAR - governing exports of national defense articles and national defense services (22 CFR Parts 120-130). Per Code 274: The processes involved in the transfer of anything to a "Foreign Person" by any means, anywhere, anytime, or the knowledge that what you are transferring to a "U.S. Person," will be further transferred to a "Foreign Person."
Correcting Posting Mistakes • Synopses • When you need to make a change or correction to a synopsis, a “modification to previous notice” should be created. You can only modify the synopsis fields to change the Response Date, Description, POC, and Place of Performance. If additional fields are required to be modified, you should coordinate with your CO/PM to determine the correct course of action. Some corrections require an entirely new synopsis, such as correcting the Solicitation or Reference Number. When making such corrections, the new synopsis should be posted first, then a modification to the original synopsis directing potential offerors to the new posting. This helps to avoid any confusions and potential conflicts. • You cannot correct these fields on the original synopsis: • Classification Code • NAICS CodeSet Aside • Noncompetitive Flag • Title • Solicitation Number • Reference Number • Document Uploads/Solicitations • When you have posted an upload (including solicitations) that contain mistakes, you should upload a revised version, and clearly identify it as such in the Title/Description. The last upload to a synopsis can be removed by the SOS Team; however it is cautioned that vendors potentially have already received communication and/or downloaded the documents.
Federal Business Opportunities – FEDBIZOPPS.GOV Unless you choose otherwise, EPS will interface NAIS posted data to the Federal Business Opportunities (FBO) site. FBO is a the government-wide point of entry for the posting of federal business opportunities. In addition, Synopses for Grant or Cooperative Agreement Awards will automatically be sent to Grants.gov. Note: Other non-federal sites may extract posted data and store it on their servers as a service for other vendors. The EPS selection is defaulted for yes for FBO postings.
Acquisition Notice Archiving When the acquisition is complete and an award is made (and, if applicable, after the justification and approval or source selection is posted), the synopsis should be archived through EPS. Archiving closed postings removes the clutter from the business opportunities listing and helps ensure the accuracy of our data. Archiving removes the posting (synopsis and all uploaded documents) from the active Business Opportunities listings, however it is still available/ retrievable from the FBO Archives search. Because archived documents are still available to the public, this is not a valid solution to address the removal of inappropriate/sensitive postings from EPS/FBO. These postings must be manually deleted from the servers. Please work with the SOS Team in these situations.
Pre-Award Public Data: eLibrary For larger acquisitions, the GSFC eLibrary houses supplemental solicitation information that is not posted to EPS (i.e., technical documents). Note: External sites should not duplicate any of the files residing on NAIS. You should work with the eLibrary point of contacts to establish your library. A link to the library should be included in your EPS Synopsis posting (see the eLibrary Setup Instructions.) Note: Just like EPS Uploads, documents should be checked for proprietary information and any necessary redactions made before they are posted to the eLibrary. Documents will not be posted to the eLibrary without PM review and approval. Remember, prior to posting any contractor historical data, ensure you have the Contractor’s consent (i.e., labor rates, labor categories, other 533 reported data).
Post-Award Public Data: It Starts With • For reporting purposes, post-award public data begins with your PRISM award data entry. Your PRISM entry should reflect what is on your official, signed copy. PRISM interfaces much of your data to the Federal Procurement Data System (FPDS). What is not interfaced is required to be completed by the Contract Specialists/Contracting Officer. • A signed copy of the award cover page should be uploaded in PRISM to facilitate FPDS validation. Your data is validated and approved by our Support Contractor, DTI, with assistance from the SOS Team, based on the signed copy, and other supporting information. • Remember FPDS should be launched before your award is released in PRISM. Doing so: • Enables any FPDS Validation Errors coming from PRISM to be corrected via PRISM such as adding a missing Inherently Government Function (IGF) Service Identifier in your Description for any Service Awards. • Eliminates the need for manual FPDS entries/corrections • Ensures PRISM and FPDS are in sync for accuracy and reporting purposes • Reduces the number of system correction actions required after the PRISM award is released
Post-Award Public Data: It Starts With Reported FPDS data must be able to be matched up to an official award document and its contents. The responsibility for the completion and accuracy of the individual contract action report (CAR) resides with the Contracting Officer who awarded the contract action (FAR 4.604). Note: If its not included in the official, signed award (or file contents), it’s not reported in FPDS, regardless of what is entered in PRISM (i.e., PRISM and Hard Copy have different End Dates.)
What is FPDS? In accordance with the Federal Funding Accountability and Transparency Act of 2006 (Pub. L. 109-282), all unclassified Federal award data must be publicly accessible. Accordingly, FPDS maintains publicly available information about all unclassified contract actions exceeding the micro-purchase threshold. FPDS contains summary level information about the financial award, along with other required reporting elements such as type of set-aside and specific contract clauses. FPDS is also a basis for recurring and special reports to the President, the Congress, the Government Accountability Office, Federal executive agencies, and the general public.
It Doesn’t End With FPDS • The accuracy of the Contracting Officer approved FPDS data is vital. In addition to being housed on the FPDS site, it is also extracted, or interfaced, by various other sites: • The SBA submits an annual Small Business Goaling Report with achievements against the goals to Congress. The report is generated by FPDS-NG. The official Small Business Goaling Report is published on the SBA website, www.sba.gov • USASpending.gov contains information about procurements, grants, and loans. It is updated with FPDS-NG data on a monthly basis. It also Includes sub-contract and sub-grant data reported by the Prime Vendors through FFATA Subaward Reporting System (FSRS). • NASA Procurement Data View (NPDV) is an on-line query database system containing summary-level award data (e.g., contract number and description, contractor and address, period of performance, value) on all active NASA contracts. Includes fiscal year, geographic, and ad hoc query capabilities. • The Interagency Contract Directory (ICD) is a central repository of Indefinite Delivery Vehicles (IDV) awarded by the Federal agencies where the IDV is available for use at both the intra agency and interagency levels.
Remember FPDS Data is Meant for the Public HQs, SBA, and congressional staff monitor your FPDS data. When reported data raises questions, the Centers are asked to address it. Example of previously questioned data: Attached is a file showing awards that are being questioned by the SBA as to the validity of the CO's Business Size Selection field…. The Description of Requirement is not satisfactorily completed; the more succinct and accurate is better. Also remember that ALL R&D awards must contain a 300-500 word description of the work being performed. The attached spreadsheet shows awards that are coded as small business, but when I (HQ) checked ORCA/CCR and now SAM, they show as not being small for the NAICS used on the award… Attached is a spreadsheet showing awards where Davis Bacon Act is coded either No or Not Applicable but the NAICS code used is for construction and the obligation amount is greater than $2,000 (See FAR 22.403-1). …The second question has to do with the relationship between the description and the PSC and NAICS. The PSC and NAICS are for books and pamphlets and periodical publishing. However, the description says the contractor is providing counseling services for individuals and class complaints of discrimination…. They just don’t seem to go together…. ACTION! Press inquiry- check these records!!!!! We have heard that there is a press inquiry about awards made to the New York Times being marked as small by the Contracting Officers. I've attached a list here of actions where the parent organization is the NY Times…. OMB is now pulling data directly from FPDS to track the progress of agencies in the area of sustainable acquisition. According to the data in FPDS, NASA is doing poorly in this area….