From: NASA Office of Inspector General
Posted: Saturday, October 30, 2004
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National Aeronautics and
Space Administration Office of Inspector General
Washington, D.C. 20546-0001
Reply to Attn of: W
October 20, 2004
TO: Deputy Chief Acquisition Officer/Director for Procurement
Director, Ames Research Center
Director, Goddard Space Flight Center
Director, Johnson Space Center
FROM: Assistant Inspector General for Auditing
SUBJECT: Final Memorandum on Management of NASA Procurement Workforce
Assignment Number A-03-024-00
Report Number IG-05-002
We conducted an audit of the management of the NASA procurement workforce to determine whether NASA defined its procurement workforce consistent with the Office of Federal Procurement Policy's (OFPP) definition, adequately addressed the training needs of that workforce, adequately addressed procurement workforce attrition, and initiated additional actions to address future procurement workforce planning. We performed audit work at Ames, Goddard, Headquarters, and Johnson. Enclosure 2 provides details on the objectives, scope, and methodology of the audit.
The President's Management Agenda places emphasis on Human Capital issues in the Federal workforce. Because NASA spends 85 to 90 percent of its budget through procurements each year, effective management of the procurement workforce is especially critical for the Agency. During the audit, we identified management control weaknesses for ensuring that designated Contracting Officer Technical Representatives (COTRs) received the required training. We found that, in some cases, COTRs lacked the required training necessary to carry out their delegated duties and responsibilities.
We made five recommendations to Agency management geared toward ensuring that all designated COTRs receive the required training necessary to effectively perform their contract oversight duties and responsibilities. Management concurred with all of our recommendations and has taken appropriate corrective action.
In addition to the Presidential emphasis on Human Capital issues in the Federal workforce, the Government Accountability Office (GAO) has highlighted Human Capital as a management challenge for Federal agencies. Because NASA spends 85 to 90 percent of its budget through procurements each year, NASA has initiated a number of acquisition reform initiatives to streamline the acquisition process including the effective management of the procurement workforce.
We found that NASA defined its procurement workforce generally consistent with the OFPP definition. In OFPP Policy Letter 97-01, dated September 12, 1997, OFPP defines an agency's acquisition workforce to include (1) all positions in the General Schedule (GS-1102) contracting series; (2) all contracting officers regardless of GS series with authority to obligate funds above the micropurchase threshold; (3) all positions in GS-1105 purchasing series; and (4) all COTRs or equivalent positions. We also found that the Agency adequately addressed procurement workforce attrition and initiated appropriate actions addressing future procurement workforce planning. Our analysis of hires and losses at the installations reviewed indicated that NASA has taken steps to address workforce attrition by implementing programs that facilitate the hiring, development, and retention of procurement professionals. Additionally, each installation reviewed had either taken or initiated actions to address future procurement workforce planning (for example, using NASA's Cooperative Education and Contracting Intern programs to bring in entry-level procurement professionals).
NASA's Office of the Chief Financial Officer/Procurement Directorate has Agency-wide responsibility for functional management, leadership, and policy direction of procurement activities. Installation program offices are responsible for ensuring that COTRs possess the necessary training commensurate with the duties and responsibilities for which they will be delegated. Installation procurement personnel are required to verify that delegated COTRs have received the mandatory basic training before duties are delegated. Although the Office of the Chief Financial Officer/Procurement Directorate instituted a career development program designed to provide procurement professionals with the type of standardized and consistent training that adequately addresses the training needs of the workforce, controls over the training of COTRs needed improvement. Specifically, we found that of the 1,593 designated NASA COTRs at the 4 installations reviewed, 18 (6 active and 12 inactive) lacked the required basic training and 571 needed refresher training. For effective contract administration, all designated COTRs must be properly trained to perform the duties and responsibilities assigned to them. The problem of designated COTRs lacking the required training occurred because the installations did not effectively track and enforce COTR training. Also, although NASA's Office of the Chief Financial Officer/Procurement Directorate has Agency-wide responsibility of procurement activities, the office is not directly involved in tracking and ensuring that installation COTRs receive the required training.
We made five recommendations to ensure that all designated COTRs are effectively trained to carry out their oversight responsibilities. Specifically, we recommended that the Ames and Johnson Center Directors ensure that active COTRs at the respective centers who have not had basic COTR training take the mandatory basic training. We also recommended that the Deputy Chief Acquisition Officer/Director for Procurement coordinate with the Center Directors and Procurement Officers to ensure that all active COTRs have the necessary refresher training. We further recommended that the Deputy Chief Acquisition Officer/Director for Procurement revise the NASA Far Supplement to incorporate a clear policy for the frequency of refresher training. Finally, we recommended that the Deputy Chief Acquisition Officer/Director for Procurement track and enforce completion of basic and refresher COTR training on an Agency-wide basis. Management concurred with all of our recommendations.
Some COTRs Lack Required Basic COTR Training
NASA Federal Acquisition Regulation (FAR) Supplement (NFS) 1842.270, "Contracting Officer Technical Representative (COTR) Delegations," requires that, with one exception, employees must complete a mandatory basic COTR training course before they can be designated as COTRs and assume delegated contract oversight responsibilities. The exception to that requirement is that the Procurement Officer may appoint a temporary COTR for no longer than 6 months on an urgent need basis without the COTR taking the required basic training. Generally, controls at the four installations reviewed were effective in ensuring that designated COTRs had the required basic training. Of the 1,593 designated COTRs, 6 active COTRs lacked the required basic training. Active COTRs are designated COTRs who are responsible for monitoring one or more NASA contracts. The six COTRs, at two NASA installations, were responsible for monitoring eight contracts valued at approximately $86.4 million in total. Enclosure 3 provides, by installation, details of COTR training data.
A summary of the specific basic COTR training data for each installation reviewed follows.
The problem of having active COTRs who lack basic training occurred because of inadequate management controls at Ames and Johnson. At the two installations, six COTRs were assigned COTR responsibilities without verification of training or proper delegation. Installation program offices did not ensure that the active COTRs possessed the necessary training commensurate with the duties and responsibilities for which they would be delegated, pursuant to NFS 1842.270(a). Also, contracting officers did not verify that the designated COTRs had received the mandatory basic training before signing the delegation forms, pursuant to NFS 1842.270(g).
For effective contract administration and oversight, all active NASA COTRs must have the required training to perform the duties and responsibilities delegated to them. Basic COTR training is also necessary and prudent because such training helps protect the interests of the individuals assigned as COTRs, since those individuals may be held personally liable for unauthorized acts.
Some COTRs Lack Refresher COTR Training
Of the 1,593 COTRs at the 4 installations reviewed, 571 needed refresher training in accordance with Office of the Chief Financial Officer/Procurement Directorate guidance. Of those 571, 70 were active COTRs who were monitoring 159 contracts valued at approximately $801 million in total. Enclosure 4 provides a breakdown, by installation, of the number of COTRs needing refresher training and number of years since their last training.
A summary of the specific COTR refresher training data for each installation reviewed is as follows.
The failure to ensure that some COTRs received refresher training occurred because the NFS included a mandatory requirement for basic COTR training, but does not include any explicit requirement for refresher training. Instead of implementing an NFS requirement pertaining to refresher training, the Assistant Administrator (AA) for Procurement [now the Deputy Chief Acquisition Officer/Director for Procurement] issued guidance, in the form of a memorandum (Enclosure 5) to installation Procurement Officers, dated September 13, 2001, requesting that each installation pursue refresher training for COTRs.
The memorandum states that, as a minimum, refresher training should be given to those COTRs who have not received comprehensive training within the last 5 years. The Audit Liaison Representative for the Office of the Chief Financial Officer/Procurement Directorate at NASA Headquarters informed us that the Deputy Chief Acquisition Officer/Director for Procurement decided to issue a memorandum in lieu of implementing an NFS requirement because the Office of the Chief Financial Officer/Procurement Directorate and the installation procurement offices did not have the authority to impose training requirements on installation program personnel. COTRs report to installation program offices, not the Deputy Chief Acquisition Officer/Director for Procurement or the installation procurement offices. Also, training budgets, including funding for COTR training, are managed by each respective installation and not the Office of the Chief Financial Officer/Procurement Directorate. Despite the memorandum from the AA [now the Deputy Chief Acquisition Officer/Director for Procurement], COTR refresher training at the four NASA installations reviewed was not sufficiently tracked and enforced because of uncertainty whether the memorandum was intended as mandatory Agency policy or simply a suggestion. The Federal procurement environment is dynamic and changes rapidly. Therefore, for effective contract administration and oversight, periodic COTR refresher training is essential to ensure that designated COTRs are aware of the most current Federal procurement regulations, policies, initiatives, procedures, and techniques relating to their COTR duties and responsibilities. A firm Agency policy requiring refresher training will help ensure consistent training of designated COTRs as well as effective tracking and enforcement of the required training.
Management's Response is included as Enclosure 6.
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