(c) Centers shall perform statistically-valid comparisons of FPDS data to contract files. The Procurement Officer Certification of Procurement Data Submissions to FPDS and the Results of Statistically Valid Comparison of FPDS Data and Contract Files shall be submitted to the Office of Procurement, Analysis Division by December 15
th of each year. The templates for these documents can be accessed at:
http://www.hq.nasa.gov/office/procurement/regs/ProcurementOfficerCertification.doc and shall be attached to a cover letter forwarding Center submittals. Definitions and specific process requirements are as follows:
(i)
Definitions:
Overall Accuracy Rate - The percent of all the FPDS data elements sampled which were determined to be correct (the elements matched the corresponding data in the contract files and the data in the contract files were correct). Only compute the overall data accuracy rate for the data elements listed in (D) for the FPDS validation, verification and certification process as required by the Office of Federal Procurement Policy (OFPP). Center validation of additional data elements must be accomplished separately.
Data Element Accuracy Rate - The percentage of entries for each selected data element in the sampled contract action records (CARs) that were determined to be correct (the entry matched the corresponding data in the contract file and the data in the contract file was correct). Only data elements appropriate for the type of record being validated should be counted in computing the data element accuracy rate. For example, only count the accuracy of the “Reason for Modification” element in modification records. Data elements that have been optional in FPDS should be validated as though they had been required. Therefore, data elements should only be blank if they do not apply to that record type. Data elements that apply to the type of record being reviewed must not be blank and must be supported by information present in the contract file or contract writing system.
Total Sample Size - This is the total number of FPDS CARs selected for comparison to the corresponding contract files. Records will be randomly identified for each Center by the HQ Office of Procurement.
Percent of Total Center Procurement Spend Covered by Sample - This is computed by dividing the total obligations associated with the CARs sampled by the total obligations associated with all procurement actions at your Center (excluding grants) during the review period.
(ii)
Procedures:
(A) All reportable Center actions must be entered into FPDS. The HQ Office of Procurement will randomly select actions (excluding grants) for data validation and verification from records in the system and provide a list of actions to each Center on or about April 15
th and October 15
th. The April list of actions will include awards made October 1 through March 31. The October list will include awards made April 1 through September 30. Centers can establish a schedule for completing the validation and verification as long as the certification and results report is provided as required in 1804.604(c).
(B) Each sampled CAR shall be validated against the associated contract file by an individual other than the contracting officer who awarded the contract or the person entering the contract data for that CAR. While validation of data against the corresponding data in the contract writing system (CWS) may still occur, for the purposes of the validation and verification process, verification must be made against the official contract file for each CAR.
(C) The reviewer(s) must obtain sufficient information to validate any CAR data elements not contained in the contract file or CWS. Data elements that cannot be validated shall be considered incorrect and this includes CAR data elements that match data in the contract file or CWS that the reviewer and his/her supervisor determine to be inaccurate.
(D) The data elements to be reviewed are identified by the names which appear on the FPDS screens and correspond to the data dictionary definition which can be accessed at
http://www.fpds-ng.com/downloads/FPDSNG_DataDictionary.pdf. The following data elements shall be reviewed as a part of the data validation and verification process:
1A Procurement Identifier
1C Referenced IDV ID
2A Date Signed
2C Completion Date
2D Est. Ultimate Completion Date
2E Last Date to Order
3A Base and All Options Value
3B Base and Exercised Options Value
3C Action Obligation
4C Funding Agency ID
4F Funded by Foreign Entity
5B Who Can Use
5D Fee for Use of Service
5J Fee Paid for Use of IDV
6A Type of Contract
6F Performance Based Service Acquisition
6M Description of Requirement
7A Clinger Cohen Act
7B Walsh-Healy Act
7C Service Contract Act
7D Davis Bacon Act
8A Product/Service Code
8G Principal NAICS Code
8K Use of EPA Designated Products
8L Use of Recovered Material
8N Bundled Contract
9A DUNS No
9C Principal Place of Performance Code
9H Place of Manufacture
9K Place of Performance ZIP Code (+4)
10A Extent Competed
10C Reason Not Competed
10N Type of Set Aside
10P Evaluated Preference
10R Statutory Exception to Fair Opportunity
11A CO’s Business Size Selection
11B Subcontract Plan
12A IDV Type
12B Award Type
12C Reason for Modification (if 12D = M)
13N 8(a) Program Participant
13O HUBZone Firm
13P Small Disadvantaged Business
13U Woman Owned Business
13V Veteran Owned Business
13W Service-Related DVOB
(E) Each Center shall utilize a sample size from the random list of contract actions that is sufficient to produce statistically valid conclusions at the 95% confidence level, with an error rate of no more than 5 percent. The contract actions must be reviewed in the sequential order provided in the list from the HQ Office of Procurement. Centers must use the
Binomial Confidence Intervals calculator at
http://statpages.org/confint.html to determine if they have achieved an error rate of no more that 5 percent in accordance with OFPP guidance. When using the calculator note the following:
Binomial Confidence Intervals
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Numerator:
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Denominator:
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Proportion:
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Exact Confidence Interval:
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Confidence Level:
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% Area in Upper Tail:
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% Area in Lower Tail:
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1. The Numerator equals the total number of errors found
2. The Denominator equals the total number of contract action records reviewed
3. The Confidence Level will always be 95
4. The percentage used in the Upper Tail block will always be five (5)
5. The percentage in the Lower Tail block will always be zero (0)
6. The Exact Confidence Interval and the Proportion are automatically computed when the
numerator and denominator are inserted. An exact confidence Interval greater than 5 percent
exceeds the OFPP tolerance level.
(F) Errors or discrepancies identified must be documented and corrected in FPDS and PRISM/CMM. Current year awards will be provided in the list of actions, but if an error has been carried forward from the basic award, the basic award must be corrected so that the change carries forward to all modifications. In addition to the Results of Statistically Valid Comparison of FPDS Data and Contract Files report that accompanies the Procurement Officer’s certification, each Center shall maintain a record of all findings, corrections, and the date(s) corrections were made in CMM and/or FPDS. When requested, this information shall be provided to the Office of Procurement, Analysis Division.
(G) Errors in fields that originate from external sources (i.e. CCR data and basic contract award information input by another agency (when placing orders)) cannot be corrected by NASA. Each occurrence must be counted as an error and identified in the results report if this is considered to be the cause of systemic errors for a data field being reviewed. Specific descriptions of these errors shall be maintained in the Center record of findings.
(H) Each center shall identify a primary focal point and one alternate for FPDS data verification and validation responsibility. The focal point is responsible for establishing and coordinating the center’s review process and ensuring that reviews comply with the requirements of this section and the OFPP mandate for independent review of contract actions against the contract file. The focal point shall also ensure that certifications are provided to the Office of Procurement, Analysis Division on or before the December 15th due date each year. Focal point and/or alternate changes shall be promptly provided to the Analysis Division.
(I) Each center shall develop and maintain an FPDS Data Quality Plan. The template for the plan is available at: http://www.hq.nasa.gov/office/procurement/regs/QualityPlan. The focal point shall ensure that the most current copy/version of the Center’s Data Quality Plan is provided to the Office of Procurement, Analysis Division.
