Contract Management: Few Competing Proposals for Large DOD Information
Technology Orders (Letter Report, 03/20/2000, GAO/NSIAD-00-56).
Pursuant to a congressional request, GAO provided information on the
Department of Defense's use of large orders under multiple-award
contracts to acquire information technology products and services,
focusing on: (1) whether contractors were provided a fair opportunity to
be considered and the extent of competition realized; and (2) how
ordering offices met requirements to clearly specify the tasks to be
performed or property to be delivered under the orders.
GAO noted that: (1) many of the 22 large orders GAO reviewed were
awarded without competing proposals having been received; (2) agencies
made frequent use of the statutory exceptions to the fair opportunity
requirement; (3) further, contractors frequently did not submit
proposals when provided an opportunity to do so; (4) only one proposal
was received in 16 of the 22 cases--the 16 cases all involved incumbent
contractors and represented about $444 million of the total $553 million
awarded; (5) contractor representatives told GAO that if program
officials were interested in receiving competing proposals, then more
outreach activities--such as meetings with potential contractors to
explain requirements--should be conducted; (6) work descriptions for
most orders reviewed defined tasks broadly; (7) most of these orders
were for information technology services and frequently covered several
years of effort; (8) because the work was broadly defined, the orders
did not establish fixed prices for the work but provided for
reimbursement of contractors' costs; (9) further, several broadly
defined orders were later defined by sole-source work orders; and (10)
according to program officials, specifying the information technology
services that will be required in future years involves considerable
uncertainty.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-00-56
TITLE: Contract Management: Few Competing Proposals for Large DOD
Information Technology Orders
DATE: 03/20/2000
SUBJECT: Procurement practices
Defense procurement
ADP procurement
Department of Defense contractors
Indefinite delivery contracts
Contract oversight
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GAO/NSIAD-00-56
A
Report to Congressional Requesters
March 2000 CONTRACT MANAGEMENT
Few Competing Proposals for Large DOD Information Technology Orders
GAO/NSIAD-00-56
National Security and International Affairs Division
Lett er
B- 281493 March 20, 2000 The Honorable James M. Inhofe Chairman The Honorable Charles S. Robb Ranking Minority Member Subcommittee on Readiness and
Management Support Committee on Armed Services United States Senate
The government acquires billions of dollars' worth of information technology products and services each year, with the Department of Defense (DOD) acquiring a significant amount of its information technology needs using task- and delivery- order contracts. 1 After concerns were raised that federal agencies had avoided competition when ordering under such contracts, 2 Congress, through the Federal Acquisition Streamlining Act, imposed statutory requirements on the use of these contracts. 3 Agencies must now consider awarding multiple contracts rather than a single contract when planning a task- or delivery- order contract.
Our prior review of the implementation of multiple- award contracting showed that agencies did not consistently promote competition for orders. 4 On the basis of this work, you asked us to expand our review and to examine DOD's use of large orders under multiple- award contracts to acquire information technology products and services and assess (1) whether contractors were provided a fair opportunity to be considered and the extent of competition realized and (2) how ordering offices met requirements to clearly specify the tasks to be performed or property to be
1 A task- or delivery- order contract provides for an indefinite quantity of supplies or services (within specific limits) to be furnished during a fixed period, with deliveries scheduled through orders with the contractor. 2 Streamlining Defense Acquisition Laws, Report of the DOD Acquisition Law Advisory Panel (Jan. 1993). 3 P. L. 103- 355 (Oct. 13, 1994).
4 Acquisition Reform: Multiple- award Contracting at Six Federal Organizations (GAO/ NSIAD- 98- 215, Sept. 30, 1998).
delivered under the orders. We selected contracts managed by the Defense Information Systems Agency, the Department of Transportation, the General Services Administration, and the National Institutes of Health. We reviewed all orders with a value of over $5 million awarded for DOD
requirements between October 1, 1997, and December 31, 1998. Most of the orders involved information technology services for ongoing defense programs. Appendix I includes information on the orders we reviewed. We briefed your staff on the results of our ongoing work. Subsequently, the
National Defense Authorization Act for Fiscal Year 2000 5 required that procurement regulations be revised to identify steps agencies should take to ensure that contractors are afforded a fair opportunity to be considered for orders and that orders clearly specify all the services or supplies to be
delivered. This report contains information that can be used in developing these new regulations. Results in Brief Most of the 22 large orders we reviewed were awarded without competing
proposals having been received. Agencies made frequent use of the statutory exceptions to the fair opportunity requirement. Further, contractors frequently did not submit proposals when provided an
opportunity to do so. Only one proposal was received in 16 of the 22 cases the 16 cases all involved incumbent contractors and represented about $444 million of the total $553 million awarded. Contractor representatives told us that if program officials were interested in receiving competing proposals, then more outreach activ'ities such as meetings with potential contractors to explain program requirements should be conducted.
Work descriptions for most orders we reviewed defined tasks broadly. Most of these orders were for information technology services and frequently covered several years of effort. Because the work was broadly defined, the orders did not establish fixed prices for the work but provided for reimbursement of contractors' costs. Further, several broadly defined orders were later defined by sole- source work orders. According to program officials, specifying the information technology services that will be required in future years involves considerable uncertainty.
5 P. L. 106- 65 (Oct. 5, 1999).
This report contains recommendations that can be used in implementing the National Defense Authorization Act requirement to revise the procurement regulations and to initiate other appropriate changes to help agencies ensure that contractors are afforded a fair opportunity to be considered for orders and that orders clearly specify all the services or
supplies to be delivered. Background Task- and delivery- order contracts have historically provided an
expeditious way to fill certain government needs. These indefinite contracts are awarded when agencies can forecast a general need for a category of supplies or services. Once agencies determine the specific times and places where services or supplies are needed and the quantities required, they issue orders under these contracts. Placing orders in this manner is less burdensome administratively than awarding a series of individual contracts.
In 1993, a DOD- sponsored study panel reported that this process brought the potential for abuse. The panel's report indicated that some orders called for work beyond what contractors had competed to provide. In 1994, members of Congress expressed concern that indiscriminate use of taskand delivery- order contracts to acquire broad categories of ill- defined advisory services could diminish competition for contracts and waste taxpayer dollars. 6
To promote competition under task- and delivery- order contracts, Congress, through the Federal Acquisition Streamlining Act (FASA), established a preference for awarding these contracts to multiple firms rather than to a single company. Orders placed under such contracts must clearly specify all the tasks to be performed or property to be delivered. In
addition, agencies placing orders must ensure that except under specified circumstances each contractor is afforded a fair opportunity to be considered. FASA authorizes exceptions to the fair opportunity process
when (1) the agency's need for supplies or services is unusually urgent, (2) the agency's needs are so unique or specialized that only one contractor can provide the required quality, (3) placing the order on a sole- source basis will promote economy and efficiency because the order is a logical follow- on to a previous order issued competitively, or (4) the order must be 6 Senate Report 103- 258 (May 11, 1994).
placed with a particular contractor to satisfy a required minimum guaranteed amount. To preserve the simplicity and flexibility of task- and delivery- order contracts, Congress provided contracting officers broad discretion to define the procedures used to evaluate offers and select contractors when placing orders. Consistent with congressional intent, the
regulations implementing FASA did not mandate procedures for providing contractors a fair opportunity or for specifying the services or supplies ordered. The Office of Federal Procurement Policy (OFPP), however, has issued a guidebook that presents the Office's views on best practices in the use of task- and delivery- order contracts. 7 For example, the guidebook suggests that agencies (1) avoid awarding logical follow- on orders whose scope or costs substantially exceed those of previous orders for which contractors were provided an opportunity to be considered and (2) use fixed- price orders where appropriate.
Our prior review of the implementation of multiple- award contracting showed that agency efforts to provide fair opportunity and thereby promote competition varied among the six organizations we reviewed. Two organizations achieved consistent competition for orders, while four had more difficulty obtaining competition to fill information technology requirements. For example, one organization did not provide contractors
an opportunity to be considered for most orders issued, while another identified a preferred contractor when announcing opportunities. The procurement regulations have since been revised to prohibit designation of preferred contractors. A further revision has been proposed to reinforce key principles regarding the administration of multiple- award contracts. These revisions would, for example, require contracting officers to
document the rationale for selecting the contractor receiving an order and encourage agencies to use performance- based work statements which describe work in terms of desired outcomes instead of how the work is to be performed to the maximum extent practicable.
Few Competing Few competing proposals were received for the large orders we reviewed.
Proposals Received for Competing proposals can help contracting officers ensure they receive the best value on federal contracts. In many cases, agency officials used the Large Orders
statutory exceptions to the fair opportunity requirement and did not request competing proposals. When agency officials afforded contractors 7 Best Practices for Multiple Award Task and Delivery Order Contracting, Office of Federal Procurement Policy (July 1997).
an opportunity to be considered, they often received proposals from only one contractor. In most cases, the submitted proposals involved incumbent contractors. 8 Contractor representatives suggested that program officials and contracting officers could promote broader competition by conducting more outreach activities, such as meetings with potential contractors to explain program requirements, and obtaining feedback on contractors' capabilities.
According to agency officials, multiple- award contracting has produced substantial benefits. Officials stated that multiple- award contracts allow them to acquire services and supplies more quickly and simply, alleviating past concerns that awarding traditional contracts took too long. Expedited
ordering procedures under multiple- award contracts have also alleviated concerns that DOD may not always be able to acquire the most current information technology. Agency officials also commented that issuing multiple- award contract orders was less burdensome administratively than awarding traditional contracts. Moreover, they expressed satisfaction with the suppliers selected through multiple- award contracts. Several commented that the skills and capabilities of their contractors were critical to their program's success.
Despite these benefits, table 1 shows that 16 of the 22 orders were awarded without competing proposals. These orders represented $443. 7 million of the total $553.1 million awarded. 8 In some of these cases, the firm submitting the proposal was the incumbent contractor or a subcontractor to the incumbent. In other cases, the firm submitting the proposal indicated that it planned to award a subcontract to the incumbent contractor or to one of the incumbent's key subcontractors.
Table 1: Competing Proposals Received
Dollars in millions
Exception Fair to fair
opportunity Orders
opportunity provided Total Orders awarded on the basis of one proposal
Number of orders 10 6 16
Value of orders $172.5 $271. 2 $443. 7 Orders awarded on the basis of competing proposals
Number of orders - 6 6
Value of orders - $109. 4 $109. 4 Total Number of orders 10 12 22 Value of orders $172.5 $380. 6 $553. 1
Note: Dollar amounts are the values of orders at the time of award, including any options.
Officials Used For 10 orders, agency officials used statutory exceptions to the fair Exceptions to Fair opportunity requirement allowed by FASA, and did not request competing
proposals. For 7 of these 10 orders, officials used the exception for logical Opportunity
follow- on orders. For three other orders, officials used exceptions for Requirement requirements that are unique and highly specialized or unusually urgent. We found that when deciding whether to award noncompetitive orders,
contracting officers relied on a statement by program officials indicating that the exception was applicable. Contracting office files did not include an analysis of the exception's applicability.
The logical follow- on exception may be used only when an original order has been awarded through the fair opportunity process. We examined the awards of these original orders and found that although six of the seven had been awarded using the fair opportunity process, competing proposals were received for only two of the original orders. Each of the seven original orders was issued to a team that included incumbent contractors.
In one of these seven cases, contrary to FASA requirements, the agency had not provided other contractors an opportunity to be considered for the original order. In April 1997, the Defense Information Systems Agency awarded a multiple- award contractor an order covering about $300,000 of
work over a 2- month period to develop a system used in material management. The agency did not provide other contractors an opportunity to be considered for this order because the program manager stated that the services were unique and highly specialized. Shortly thereafter, the agency awarded a second order covering another 10 months of work at an estimated cost of $6.7 million as a logical follow- on to the initial $300,000 order. Finally, the agency awarded the order included in our review a $7- million order covering another 11 months of work as a logical follow- on to the two previous orders. Thus, contrary to FASA, other contractors were not provided an opportunity to be considered for the work.
OFPP's best practice guidebook suggests that follow- on orders should not be substantially broader in scope and dollar value than the original competitive order. Contrary to this guidance, three of the seven logical follow- on orders were substantially broader in scope or dollar value than the original orders for which the agency had provided an opportunity for competition. For example, one order, awarded under a National Institutes of Health contract, called for $1.6 million in support for Army communications systems over 1 year. Although the National Institutes of Health provided its contractors an opportunity to be considered for this order, only one contractor chose to submit a proposal. The order we
reviewed, awarded noncompetitively as a logical follow- on to the $1. 6 million order, provided for $32.1 million in effort over 45 months, or about $8. 5 million annually. The work description for this follow- on order includes two task areas the original order's work description does not mention. To accomplish the work under the follow- on order, the contractor proposed to increase staffing to a level almost three times that proposed
for the original order. Further, the contractor proposed to increase expenditures for other direct costs such as supplies and equipment to about $2. 6 million annually compared with about $37,000 under the original order. Thus, this logical follow- on order was inconsistent with OFPP's best practice guidance.
Few Competing Proposals For 12 of the 22 orders, agencies provided contractors a fair opportunity to Were Received When be considered, but they received few competing proposals. In six cases, a
Contractors Were Provided single proposal was received. While many factors can influence the extent Opportunities
of competition for orders, the presence of an incumbent contractor appears to have been an important factor for the orders we reviewed. Ten of these 12 orders were awarded to fill an ongoing requirement for services. In all but 1 of these 10 cases, all proposals received involved incumbent
contractors. There were no incumbent contractors for the other two orders, which were to fill new requirements for services. Three proposals were received for one of these orders, and four were received for the other.
In some cases, it was apparent that incumbent contractors had an inherent advantage in competing for an order. For example, the Department of Transportation awarded a $23.7- million order to support a Navy intelligence command over 5 years (including options) and asked
contractors to submit proposals in late August to begin work in early October. To provide the required support, contractors would have needed to station about 40 staff at the Navy installation within days after the order was awarded. Staff would have required security clearances and knowledge of the command's information technology system. While
command representatives had been considering options for renewing their existing support contract for about 6 months, they had not initiated any contacts to explain their requirements to other contractors. The representatives indicated that the incumbent contractor had been performing satisfactorily. Only one proposal was received: from the incumbent, who already had staff in place providing similar services.
Further, the incumbent had been supporting the Navy program office for over 20 years and had developed, integrated, and maintained the information system. The contracting officer indicated that it would have been difficult for a competing firm to put together a winning proposal.
Another order, awarded by the General Services Administration, further illustrates the natural advantages incumbent contractors can have in competing for work. This order provided for the contractor to support Army communications systems over 4 years (including options) at an estimated cost of $149. 2 million. The solicitation indicated that contractors would be required to provide a hardware and software laboratory and testing facility equipped for work on specific makes and models of equipment. Army officials had not held meetings with other contractors to explain their requirements or obtain feedback on other contractors' capabilities. The one contractor that submitted a proposal for this order, the incumbent, already had a laboratory and testing facility in place.
Agencies sometimes used practices not designed to elicit competing proposals. For example, one $11.1- million order announced under the National Institutes of Health contracts covered over 3 years of support (including options) for an Air Force intelligence command. The agency asked contractors to submit proposals within 2 days. Command representatives told us that they were satisfied with the incumbent
contractor's performance and that they had not held meetings to explain their requirements to other contractors. One proposal was received for the order, again from the incumbent contractor. According to command representatives, the main purpose of the order was to obtain the services of a specific employee of the incumbent contractor who had special expertise. Documents in the contract files indicate that the command
planned to award the order to the incumbent contractor before the opportunity was announced. We also noted short time frames for submitting proposals for other National Institutes of Health orders. The agency's guidelines now provide that contractors will generally be provided a minimum of 5 days to submit proposals.
In our discussions with contractor representatives, we gained some insight into the factors firms consider when deciding whether to submit a proposal for an order. Contractor representatives emphasized that the decision entails a business judgment about their prospects of winning the bid because preparing a proposal is costly. Contractor representatives cited several factors that can contribute to a decision not to submit a proposal. For example, a company may be reluctant to pursue an opportunity if an incumbent contractor exists, is perceived as having strong qualifications,
and is performing well. If the company does not excel in that particular type of work, it may be inclined not to submit a proposal. Other factors that can discourage a company from submitting a proposal are unreasonably short time frames for preparing proposals and starting work and selection criteria that appear to favor incumbent contractors. By contrast, if the company perceives that its skills and qualifications are superior to the incumbent's or that the incumbent is a weak performer, it would be more inclined to pursue an opportunity.
Contractor representatives indicated that lack of agency outreach or market research activities is another factor that can discourage a company from submitting a proposal. One outreach activity, for example, is to hold formal conferences or individual meetings with contractors to explain the program's requirements and obtain feedback on contractors' capabilities. Contractor representatives considered this type of exchange a key step to fostering competition. In cases where the incumbent contractor has strong
qualifications and is performing well, the prospects of encouraging other contractors to compete would be limited. Nonetheless, armed with a good understanding of the program's requirements, a contractor can make a better informed decision on whether to pursue the bid. Further, if the contractor decides to pursue the bid, it can more quickly prepare a
responsive, quality proposal and is thus in a better competitive position.
Work Descriptions for Work descriptions for the large orders we reviewed generally defined tasks
Large Orders Defined broadly. Twenty of the orders were for information technology services.
These orders frequently covered several years of effort and, because they Tasks Broadly defined the work broadly, they did not establish a fixed price for the work but provided for reimbursing contractors' costs. According to program
officials, identifying the information technology services that will be required in future years involves considerable uncertainty.
FASA requires that orders include a work description that clearly specifies all tasks to be performed. OFPP, in its best practice guidebook for multiple- award contracts, stresses that orders must clearly define the services ordered. In particular, the guidebook indicates that agencies should not award large, undefined orders and subsequently issue solesource
work orders for specific tasks. The guidebook also endorses the use of fixed- price orders where appropriate. According to procurement regulations, establishing a fixed price for work can be appropriate when a
reasonably definite description of the work can be developed. Fixed prices also provide an incentive for contractors to control costs and perform efficiently. Most orders for services, however, described the work in broad categories, and in some cases, the agencies issued work orders to define specific tasks after the order was awarded. For example, the General Services Administration awarded one order to provide information technology support services for a Navy detachment over 3 years (including options). The order stated that the contractor would provide various types of support technical, project management, systems engineering, procurement, training, and testing in connection with the detachment's review of communications equipment or subsystems for use on Navy ships.
The order did not specify the types of equipment or subsystems that would be reviewed. The details of the tasks to be performed were to be negotiated by program officials and the contractor after the order was awarded.
Another order that laid out broad categories of services was awarded under a National Institutes of Health contract. This $18.6- million order provided support for a Navy command's electronic commerce and electronic data interchange activities over 5 years. The order provided for reimbursing the
contractor's costs. The work description identified numerous categories of services the contractor would provide. Among the required services, the work description listed helping to develop and implement interfaces between systems, analyzing security requirements and implementing
security solutions, analyzing and developing electronic commerce transaction sets, and operating an electronic commerce demonstration lab. In addition to these required services, the order included optional work that the contractor might provide. These optional services included evaluating proposed changes to system configurations and implementing approved configuration changes, preparing briefings and papers in support of the program, and providing support to program- related task groups and
action teams. When the program notifies the contractor that specific work is needed, the contractor is to develop a management plan for the task that describes the planned technical approach and includes time frame and resource estimates. According to the program manager, the work description was designed to encompass all the work that might be required during the 5- year period.
The orders we reviewed frequently covered multiple years of effort. Program officials cited the rapid evolution of information technology and the need to accommodate changes in DOD's program requirements as reasons why forecasting long- term needs was difficult. Therefore, they
said, work descriptions must be sufficiently flexible to accommodate the evolution of requirements. We were told that flexibility is particularly important when orders cover work required several years into the future.
Conclusions Congress has expressed concerns that agencies could waste taxpayer dollars in the absence of competition. The National Defense Authorization Act for Fiscal Year 2000 requires that the procurement regulations be revised to identify steps agencies should take to ensure that contractors are
afforded a fair opportunity to be considered for orders and that orders clearly specify all the services or supplies to be delivered. Competition helps federal agencies ensure the best value is obtained in awarding contracts. We found that few competing proposals were received for millions of dollars' worth of orders we reviewed. Lack of agency outreach can discourage companies from competing for orders. We also
found that broad work descriptions for task and delivery orders did not promote the use of fixed- price orders.
Recommendations We recommend that the Administrator of OFPP, as chair of the Federal Acquisition Regulatory Council, seek to develop and incorporate guidance to make it clear that agencies should not (1) award follow- on orders whose scope or costs significantly exceed those of orders for which
contractors were provided an opportunity to be considered or (2) award large undefined orders and subsequently issue sole- source work orders for specific tasks and
encourage contracting officers to use fixed- price orders to the maximum extent practicable. Further, we recommend that the guidance encourage agencies to conduct more outreach activities when providing contractors an opportunity to be considered for orders.
Agency Comments OFPP, the National Institutes of Health, the Department of Transportation, DOD, and the General Services Administration reviewed a draft of this report. OFPP stated that it shares the general concerns underlying the recommendations but is not prepared to endorse specific changes at this time. OFPP fully agreed that further review of current practices and polices surrounding the issues raised in the report is warranted to ensure that customers are enjoying the benefits of multiple- award contracts. OFPP is looking at current guidance to determine what additional changes might help agencies in their planning to avoid situations where initial orders of limited scope lead to noncompetitive awards of orders of a much larger magnitude. OFPP is looking at how modular- contracting principles can be
better applied by customers to avoid issuing unnecessarily large orders and inadequately defined orders. A proposed regulatory change would emphasize the preference for performance- based statements of work,
which OFPP expects would result in greater use of fixed- price orders. OFPP shares our concern that effective communications between customers and multiple- award contract holders is critical if agencies are to take full advantage of the highly competitive environment that multipleaward
contracts offer to meet agencies' needs. OFPP stated that it appreciates that dialogue is necessary to improve communications and to ensure that requirements and risks are well understood in order to help contract holders and customers prepare well- defined solutions and achieve the benefits of competition. OFPP's comments are in appendix II.
The National Institutes of Health concurred with our recommendations and provided written comments (see app. V). The Department of Transportation reviewed a draft of this report but provided no comments. DOD reviewed a draft of this report and stated that it concurred with two of
our three recommendations. DOD's written comments are in appendix III. DOD and the General Services Administration expressed concern with one of our recommendations, as discussed below. The General Services Administration's written comments are in appendix IV.
DOD and the General Services Administration questioned our recommendation that guidance be developed to encourage agencies to conduct more outreach activities when providing contractors an
opportunity to be considered for orders. DOD observed that in view of the numerous reasons we cite in our report for contractors' decisions not to submit proposals, government outreach might be of limited effectiveness. The General Services Administration expressed doubt that exchanges of information before a solicitation would be a major factor in contractors' decisions. While we believe it would be unrealistic to expect any one
initiative to ensure multiple proposals are received for all orders, the contractors we met with told us that outreach would be helpful in fostering more competition. Therefore, we believe agencies should conduct more outreach activities if they want to encourage contractors to submit competing proposals. As a result, we still believe our recommendation for
greater outreach is appropriate. The General Services Administration also objected to our draft report title that characterized competition for orders as limited. In particular, the General Services Administration does not believe that competitive offers
can be achieved only through multiple proposals. We acknowledge that the fact that an agency receives only one proposal does not demonstrate that the proposal is not a competitive offer. We revised the report title to address the General Services Administration's concern.
Scope and To examine DOD's placement of large orders under multiple- award, task- Methodology
and delivery- order contracts, we reviewed the legislative history of provisions relating to multiple- award contracts and the procurement regulations implementing these provisions and held discussions with OFPP officials responsible for monitoring implementation of the provisions. Because no governmentwide listing of multiple- award contracts for information technology was maintained, we judgmentally selected multiple- award contracts for review. The four contract programs selected
are administered by the charter members of the Governmentwide Agency Contracts Program Managers Council a group formed to establish standards for and promote more effective management of governmentwide contracts. The contract programs selected were the Defense Information Systems Agency's Defense Enterprise Integration Services II contracts; the Department of Transportation's Information Technology Omnibus Procurement contracts; the General Services Administration's 9600' contracts; and the National Institutes of Health's Chief Information
Officer Solutions and Partners contracts. We examined orders placed under these contracts to support DOD's activities and awarded between October 1, 1997, and December 31, 1998, and reviewed all orders valued at $5 million or more.
To assess agency ordering procedures and determine the extent of competition, we discussed award procedures for orders with agency officials and reviewed agency guidance relating to the ordering process. In addition, for each order reviewed, we examined documentation in the contracting files to ascertain the extent of competition evident for the order. We reviewed statements of work to assess whether the work descriptions clearly specified the tasks to be performed or supplies to be delivered. We also held discussions with contracting officials to obtain
information about any barriers to or limitations on competition and about any impediments to clearly specifying the tasks or supplies ordered. We held discussions with representatives from program offices acquiring
services and equipment through the orders we reviewed to understand their role in the award process and obtain their perspective on the issues being examined. Finally, we held discussions with officials of selected contractors to obtain their perspectives on barriers to competition and on how orders specified tasks.
We conducted our review from February 1999 through February 2000 in accordance with generally accepted government auditing standards.
We are sending copies of this report to Senator John Warner, Chairman, and Senator Carl Levin, Ranking Minority Member, Senate Armed Services Committee, and other interested congressional committees. We are also sending copies of this report to the Honorable William S. Cohen, Secretary
of Defense; the Honorable Donna E. Shalala, Secretary of Health and Human Services; the Honorable Rodney E. Slater, Secretary of Transportation; the Honorable David J. Barram, Administrator of General
Services; and the Honorable Jacob J. Lew, Director, Office of Management and Budget. We will make copies available to others on request. Please contact me at (202) 512- 4841 if you have any questions concerning this report. Key contributors to this assignment are listed in appendix VI. Louis J. Rodrigues Director Defense Acquisitions Issues
Appendi Appendi xes x I
Information on Selected Orders Dollars in millions
Incumbent involved in Cost or
Work duration winning team b
Agency and contract/ order Order price a fixed price (months) a (yes or no)
Defense Information Systems Agency Defense Enterprise Integration Services contracts
Defense Megacenter Operations $5. 3 Fixed price 12 Yes This order provided for services that encompass all aspects of technical and operational support for the Department of Defense (DOD) computer center located in Montgomery, Alabama. Services included computer system operations and management, help desk support, specialized training, and special studies and analyses.
DOD Electronic Commerce Program $5. 2 Cost 8 Yes This order provided for services to support development and fielding of improved electronic commerce and electronic data interchange systems within DOD. Key efforts included integrating the Defense Travel System and Defense Finance and Accounting Service systems into DOD's electronic commerce network.
Distribution Standard System $8. 1 Cost 18 Yes This order provided for services to support development of a standard management system for DOD supply depots. These services included designing and testing essential software changes, providing expertise for software enhancement, and implementing changes at operational sites.
Global Air Transportation Execution System $14. 0 Cost 14 Yes This order provided for services to continue development of an improved air transportation management information system. The effort included systems engineering, software coding, integrating components, system installation, testing, and training.
Global Decision Support System $6. 4 Cost 12 Yes This order provided for services to continue modernization of an air transportation command and control system. These services included defining hardware and software requirements, developing and integrating software applications, providing training, and providing system and software maintenance.
Maintenance Planning and Execution System $7. 0 Cost 11 Yes This order provided for services to support development and fielding of a standard management system for DOD maintenance depots. These services included completing design and development of an updated version of the system, installing the system at selected locations, and providing ongoing support for installed systems.
Department of Transportation Information Technology Omnibus Procurement contracts
Defense Computer Forensic Lab Support $6. 4 Cost 41 No This order provided for services to support operation of a laboratory that analyzes computer- based information gathered during criminal investigations. The scope included services to support the functions of computer systems administrators, forensic examiners, evidence custodians, database analysts, and office managers.
Army Defense Message System $30. 5 Cost 59 Yes This order provided for technical support services for all aspects of design, testing, and implementation of the Defense Message System at Army installations. Efforts included conducting site surveys, developing site implementation plans, installing and integrating components, and conducting training.
Atlantic Command On- line System $23. 7 Cost 60 Yes This order provided for systems management and information technology support services for the Navy Atlantic Command and Atlantic Intelligence Command. These services included systems engineering, architecture planning, information technology evaluation, and training support.
Continued
Dollars in millions
Incumbent involved in Cost or
Work duration winning team b
Agency and contract/ order Order price a fixed price (months) a (yes or no)
Joint Strike Fighter Program Office Local Area Network Support $17. 2 Cost 60 Yes This order provided for services to support all aspects of design, acquisition, and implementation of program office information systems. Specific services included administering the local area network, providing a user help desk, supporting Internet and e- mail services, and providing infrastructure support.
Transportation Coordinators' Automated Information for Movements System $35. 9 Cost 60 Yes This order provided for services to continue developing a standard transportation management system for DOD fighting units. The services included software engineering, application development, integrated logistics support, and testing.
General Services Administration 9600 contracts
Air Mobility Command Command and Control Systems $26. 1 Cost 60 Yes This order provided for services and related hardware and software to support a range of command and control systems. The services included strategic program management, software development and maintenance, database administration, testing, training, and customer support. Joint Professional Military Education Program $5. 5 Fixed price/ cost 24 No This order provided for services to design and implement upgraded training tools for the Armed Forces Staff College. These services included planning for curriculum enrichment, analyzing requirements and developing designs for training tools, and implementing a final system design.
Naval In- service Engineering Detachment $51. 3 Cost 36 Yes This order provided for services to support the design and integration of communications systems aboard the Navy fleet. These services included support for project management, technical reviews, training, system engineering, system integration, test and evaluation, and procurement.
Reserve Component Automation System $18. 2 Cost 60 Yes This order provided for services to help manage development of an automated system to support operational and administrative tasks for the Army National Guard and Reserves. These services included support for functions such as independent evaluation, strategic
planning, systems engineering, and project management. Worldwide Technical Control Improvement Program $149. 2 Cost 48 Yes This order provided for services to help the Army Communications- Electronics Command upgrade control facilities for the Army's longhaul communications systems. These services included support for functions such as procurement and production, equipment installation, and training.
National Institutes of Health Chief Information Officer- Solutions and Partners contracts
Air Intelligence Command Support $11. 1 Cost 44 Yes This order provided for services to help maintain and upgrade computer network infrastructure for the Command's 480th Air Intelligence Group. These services included engineering support for the enhancement of several systems, hardware installation, network operations support, and year 2000 remediation support.
Defense Megacenter Central Processing Units $65. 2 Fixed price 8 Yes This order provided for central processing units to upgrade data processing capabilities at various DOD computer centers.
Continued from Previous Page
Dollars in millions
Incumbent involved in Cost or
Work duration winning team b
Agency and contract/ order Order price a fixed price (months) a (yes or no)
Defense Megacenter Disk Drives $10. 7 Fixed price 6 Yes This order provided for disk drive units to upgrade data processing capabilities at various DOD computer centers. Digital Communications Satellite Subsystem $32. 1 Cost 45 Yes This order provided services to support equipment that provides signal processing and jamming protection for the Defense Satellite Communications System. These services included analyzing and determining requirements, conducting research and evaluations, and developing site engineering plans.
Military Sealift Command Electronic Commerce $18. 6 Cost 60 Yes This order provided services to support the Command's electronic commerce initiatives. These services included helping develop and implement interfaces between systems, analyzing security requirements, operating an electronic commerce demonstration lab, and preparing briefing papers in support of the program.
Portal Shield System Support $5. 3 Cost 23 Yes This order provided services to support development of an automated system to detect biological warfare agents. These services included production engineering and evaluation; systems engineering support; and assembly, integration, and test of initial production units of the system.
Continued from Previous Page a Order price and work duration include effort under options the government may or may not exercise.
b In some cases, the winning contractor was the incumbent contractor or a subcontractor of the incumbent. In other cases, the winning contractor indicated that it planned to award a subcontract to the incumbent contractor or to one of the incumbent's key subcontractors.
Comments From the Office of Federal
Appendi x II Procurement Policy
Appendi x II I Comments From the Department of Defense
ap3p1
See comment 1. See p. 11.
See comment 2. See comment 3. See comment 4.
The following are GAO's comments on DOD's letter, dated February 15, 2000.
GAO Comments 1. The Federal Acquisition Streamlining Act (FASA) requires that agencies placing orders under multiple- award contracts provide each contractor an opportunity to be considered unless one of the statutory exceptions applies. DOD stated that it might be appropriate for the ordering office to announce its intention to award to one of the multiple- award
contract holders. Office of Management and Budget officials concluded that the practice of identifying a preferred source, as announcing intentions to award to a contractor would do, discourages competition
and deprives the government of the benefits of efficiency and innovation that competition provides. Further, federal procurement regulations were revised to prohibit agencies from designating preferred sources.
2. Although the governmentwide policies relating to multiple- award contracts have been in place for over 4 years, additional training in these policies would no doubt produce benefits. However, we believe that the additional guidance we recommend is needed to foster increased competition for orders.
3. It is not clear to us whether the Civilian Personnel Management Service intends to endorse expanded use of time and materials contracts despite the recognition that this contracting method is generally not advantageous to the government.
4. Our concern was that a contractor might be denied the opportunity to compete for a large follow- on order because the contractor had decided not to submit a proposal on an original order with a narrow scope or insignificant dollar value. The Navy's suggestion represents one option for alleviating this concern. However, we believe the
original orders would have to provide enough details of the scope and anticipated dollar value of future work to allow sound contractor decisions on whether to compete for the work. In view of program officials' comments about the difficulty of forecasting long- term
information technology needs, it is likely that few details of the scope and anticipated dollar value of future work could be provided.
Comments From the General Services
Appendi x V I Administration
See p. 8.
See comment 1. See p. 12. See comment 2. See comment 3.
The following are GAO's comments on the General Services Administration's letter, dated February 22, 2000. GAO Comments 1. As the General Services Administration points out, agencies are not required to structure a solicitation so as to neutralize the incumbent's
advantage. We did not suggest that agencies should neutralize the incumbent's advantage. We stated that agencies could encourage competition for some orders by helping prospective contractors understand the agency's requirements. However, for the orders reviewed, the presence of an incumbent contractor appeared to be an important factor influencing the extent of competition. As we note in
our report, 10 of the 12 orders where contractors were provided an opportunity to be considered were issued to fill ongoing requirements for services. In all but 1 of these 10 cases, all proposals received involved incumbent contractors. While incumbency presents
significant advantages, a number of contractors told us that market outreach activities promote competition and allow firms to prepare better proposals. 2. The guidance the General Services Administration cites discusses the
relative importance of cost or price compared with other factors in selecting a source and does not address the desirability of establishing a fixed price. We recognize that it is sometimes not appropriate to establish a fixed price for work, and we recommend that guidance
encourage the use of fixed prices where practicable. 3. According to the contract documents for this order, when Navy officials
notify the contractor of a new requirement, the contractor is to prepare a Program Master Plan for the requirement. This Program Master Plan is to include the scope and technical requirements of the project, the place and period of performance, milestones and deliverables for the project, personnel and other direct costs, and any data or materials the government will provide. The contractor is to provide a draft Plan to
Navy officials for review and concurrence before preparing a final version of the Plan. We believe the report accurately characterizes the procedures for defining new tasks under this order.
Comments From the National Institutes of
Appendi x V Health
Appendi x VI
GAO Contacts and Staff Acknowledgments GAO Contacts David E. Cooper (202) 512- 4841 Ralph Dawn (202) 512- 4544 Acknowledgments In addition to those named above, Ken Graffam, Charles Malphurs, Monty
Peters, John Van Schaik, and William T. Woods made key contributions to this report.
(707392) Lett er
GAO United States General Accounting Office
Page 1 GAO/ NSIAD- 00- 56 Contract Management
Contents Letter 3 Appendixes Appendix I: Information on Selected Orders 18
Appendix II: Comments From the Office of Federal Procurement Policy 21
Appendix III: Comments From the Department of Defense 24 Appendix IV: Comments From the General Services Administration 28 Appendix V: Comments From the National Institutes of Health 33 Appendix VI: GAO Contacts and Staff Acknowledgments 35
Tables Table 1: Competing Proposals Received 8
Abbreviations
DOD Department of Defense FASA Federal Acquisition Streamlining Act OFPP Office of Federal Procurement Policy
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Appendix I
Appendix I Information on Selected Orders
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Appendix I Information on Selected Orders
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Appendix II
Appendix II Comments From the Office of Federal Procurement Policy
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Appendix II Comments From the Office of Federal Procurement Policy
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Appendix III
Appendix III Comments From the Department of Defense
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Appendix III Comments From the Department of Defense
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Appendix III Comments From the Department of Defense
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Appendix IV
Appendix IV Comments From the General Services Administration
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Appendix IV Comments From the General Services Administration
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Appendix IV Comments From the General Services Administration
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Appendix IV Comments From the General Services Administration
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Appendix V
Appendix V Comments From the National Institutes of Health
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Appendix VI
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NS00056 A Report to Congressional Requesters March 2000 CONTRACT
MANAGEMENT Few Competing Proposals for Large DOD Information
Technology Orders GAO/NSIAD-00-56 National Security and
International Affairs Division Lett er B-281493 March 20, 2000 The
Honorable James M. Inhofe Chairman The Honorable Charles S. Robb
Ranking Minority Member Subcommittee on Readiness and Management
Support Committee on Armed Services United States Senate The
government acquires billions of dollars' worth of information
technology products and services each year, with the Department of
Defense (DOD) acquiring a significant amount of its information
technology needs using task- and delivery- order contracts. 1
After concerns were raised that federal agencies had avoided
competition when ordering under such contracts, 2 Congress,
through the Federal Acquisition Streamlining Act, imposed
statutory requirements on the use of these contracts. 3 Agencies
must now consider awarding multiple contracts rather than a single
contract when planning a task- or delivery- order contract. Our
prior review of the implementation of multiple- award contracting
showed that agencies did not consistently promote competition for
orders. 4 On the basis of this work, you asked us to expand our
review and to examine DOD's use of large orders under multiple-
award contracts to acquire information technology products and
services and assess (1) whether contractors were provided a fair
opportunity to be considered and the extent of competition
realized and (2) how ordering offices met requirements to clearly
specify the tasks to be performed or property to be 1 A task- or
delivery- order contract provides for an indefinite quantity of
supplies or services (within specific limits) to be furnished
during a fixed period, with deliveries scheduled through orders
with the contractor. 2 Streamlining Defense Acquisition Laws,
Report of the DOD Acquisition Law Advisory Panel (Jan. 1993). 3 P.
L. 103- 355 (Oct. 13, 1994). 4 Acquisition Reform: Multiple- award
Contracting at Six Federal Organizations (GAO/NSIAD-98-215, Sept.
30, 1998). delivered under the orders. We selected contracts
managed by the Defense Information Systems Agency, the Department
of Transportation, the General Services Administration, and the
National Institutes of Health. We reviewed all orders with a value
of over $5 million awarded for DOD requirements between October 1,
1997, and December 31, 1998. Most of the orders involved
information technology services for ongoing defense programs.
Appendix I includes information on the orders we reviewed. We
briefed your staff on the results of our ongoing work.
Subsequently, the National Defense Authorization Act for Fiscal
Year 2000 5 required that procurement regulations be revised to
identify steps agencies should take to ensure that contractors are
afforded a fair opportunity to be considered for orders and that
orders clearly specify all the services or supplies to be
delivered. This report contains information that can be used in
developing these new regulations. Results in Brief Most of the 22
large orders we reviewed were awarded without competing proposals
having been received. Agencies made frequent use of the statutory
exceptions to the fair opportunity requirement. Further,
contractors frequently did not submit proposals when provided an
opportunity to do so. Only one proposal was received in 16 of the
22 cases the 16 cases all involved incumbent contractors and
represented about $444 million of the total $553 million awarded.
Contractor representatives told us that if program officials were
interested in receiving competing proposals, then more outreach
activ'ities such as meetings with potential contractors to explain
program requirements should be conducted. Work descriptions for
most orders we reviewed defined tasks broadly. Most of these
orders were for information technology services and frequently
covered several years of effort. Because the work was broadly
defined, the orders did not establish fixed prices for the work
but provided for reimbursement of contractors' costs. Further,
several broadly defined orders were later defined by sole- source
work orders. According to program officials, specifying the
information technology services that will be required in future
years involves considerable uncertainty. 5 P. L. 106- 65 (Oct. 5,
1999). This report contains recommendations that can be used in
implementing the National Defense Authorization Act requirement to
revise the procurement regulations and to initiate other
appropriate changes to help agencies ensure that contractors are
afforded a fair opportunity to be considered for orders and that
orders clearly specify all the services or supplies to be
delivered. Background Task- and delivery- order contracts have
historically provided an expeditious way to fill certain
government needs. These indefinite contracts are awarded when
agencies can forecast a general need for a category of supplies or
services. Once agencies determine the specific times and places
where services or supplies are needed and the quantities required,
they issue orders under these contracts. Placing orders in this
manner is less burdensome administratively than awarding a series
of individual contracts. In 1993, a DOD- sponsored study panel
reported that this process brought the potential for abuse. The
panel's report indicated that some orders called for work beyond
what contractors had competed to provide. In 1994, members of
Congress expressed concern that indiscriminate use of taskand
delivery- order contracts to acquire broad categories of ill-
defined advisory services could diminish competition for contracts
and waste taxpayer dollars. 6 To promote competition under task-
and delivery- order contracts, Congress, through the Federal
Acquisition Streamlining Act (FASA), established a preference for
awarding these contracts to multiple firms rather than to a single
company. Orders placed under such contracts must clearly specify
all the tasks to be performed or property to be delivered. In
addition, agencies placing orders must ensure that except under
specified circumstances each contractor is afforded a fair
opportunity to be considered. FASA authorizes exceptions to the
fair opportunity process when (1) the agency's need for supplies
or services is unusually urgent, (2) the agency's needs are so
unique or specialized that only one contractor can provide the
required quality, (3) placing the order on a sole- source basis
will promote economy and efficiency because the order is a logical
follow- on to a previous order issued competitively, or (4) the
order must be 6 Senate Report 103- 258 (May 11, 1994). placed with
a particular contractor to satisfy a required minimum guaranteed
amount. To preserve the simplicity and flexibility of task- and
delivery- order contracts, Congress provided contracting officers
broad discretion to define the procedures used to evaluate offers
and select contractors when placing orders. Consistent with
congressional intent, the regulations implementing FASA did not
mandate procedures for providing contractors a fair opportunity or
for specifying the services or supplies ordered. The Office of
Federal Procurement Policy (OFPP), however, has issued a guidebook
that presents the Office's views on best practices in the use of
task- and delivery- order contracts. 7 For example, the guidebook
suggests that agencies (1) avoid awarding logical follow- on
orders whose scope or costs substantially exceed those of previous
orders for which contractors were provided an opportunity to be
considered and (2) use fixed- price orders where appropriate. Our
prior review of the implementation of multiple- award contracting
showed that agency efforts to provide fair opportunity and thereby
promote competition varied among the six organizations we
reviewed. Two organizations achieved consistent competition for
orders, while four had more difficulty obtaining competition to
fill information technology requirements. For example, one
organization did not provide contractors an opportunity to be
considered for most orders issued, while another identified a
preferred contractor when announcing opportunities. The
procurement regulations have since been revised to prohibit
designation of preferred contractors. A further revision has been
proposed to reinforce key principles regarding the administration
of multiple- award contracts. These revisions would, for example,
require contracting officers to document the rationale for
selecting the contractor receiving an order and encourage agencies
to use performance- based work statements which describe work in
terms of desired outcomes instead of how the work is to be
performed to the maximum extent practicable. Few Competing Few
competing proposals were received for the large orders we
reviewed. Proposals Received for Competing proposals can help
contracting officers ensure they receive the best value on federal
contracts. In many cases, agency officials used the Large Orders
statutory exceptions to the fair opportunity requirement and did
not request competing proposals. When agency officials afforded
contractors 7 Best Practices for Multiple Award Task and Delivery
Order Contracting, Office of Federal Procurement Policy (July
1997). an opportunity to be considered, they often received
proposals from only one contractor. In most cases, the submitted
proposals involved incumbent contractors. 8 Contractor
representatives suggested that program officials and contracting
officers could promote broader competition by conducting more
outreach activities, such as meetings with potential contractors
to explain program requirements, and obtaining feedback on
contractors' capabilities. According to agency officials,
multiple- award contracting has produced substantial benefits.
Officials stated that multiple- award contracts allow them to
acquire services and supplies more quickly and simply, alleviating
past concerns that awarding traditional contracts took too long.
Expedited ordering procedures under multiple- award contracts have
also alleviated concerns that DOD may not always be able to
acquire the most current information technology. Agency officials
also commented that issuing multiple- award contract orders was
less burdensome administratively than awarding traditional
contracts. Moreover, they expressed satisfaction with the
suppliers selected through multiple- award contracts. Several
commented that the skills and capabilities of their contractors
were critical to their program's success. Despite these benefits,
table 1 shows that 16 of the 22 orders were awarded without
competing proposals. These orders represented $443. 7 million of
the total $553.1 million awarded. 8 In some of these cases, the
firm submitting the proposal was the incumbent contractor or a
subcontractor to the incumbent. In other cases, the firm
submitting the proposal indicated that it planned to award a
subcontract to the incumbent contractor or to one of the
incumbent's key subcontractors. Table 1: Competing Proposals
Received Dollars in millions Exception Fair to fair opportunity
Orders opportunity provided Total Orders awarded on the basis of
one proposal Number of orders 10 6 16 Value of orders $172.5 $271.
2 $443. 7 Orders awarded on the basis of competing proposals
Number of orders - 6 6 Value of orders - $109. 4 $109. 4 Total
Number of orders 10 12 22 Value of orders $172.5 $380. 6 $553. 1
Note: Dollar amounts are the values of orders at the time of
award, including any options. Officials Used For 10 orders, agency
officials used statutory exceptions to the fair Exceptions to Fair
opportunity requirement allowed by FASA, and did not request
competing proposals. For 7 of these 10 orders, officials used the
exception for logical Opportunity follow- on orders. For three
other orders, officials used exceptions for Requirement
requirements that are unique and highly specialized or unusually
urgent. We found that when deciding whether to award
noncompetitive orders, contracting officers relied on a statement
by program officials indicating that the exception was applicable.
Contracting office files did not include an analysis of the
exception's applicability. The logical follow- on exception may be
used only when an original order has been awarded through the fair
opportunity process. We examined the awards of these original
orders and found that although six of the seven had been awarded
using the fair opportunity process, competing proposals were
received for only two of the original orders. Each of the seven
original orders was issued to a team that included incumbent
contractors. In one of these seven cases, contrary to FASA
requirements, the agency had not provided other contractors an
opportunity to be considered for the original order. In April
1997, the Defense Information Systems Agency awarded a multiple-
award contractor an order covering about $300,000 of work over a
2- month period to develop a system used in material management.
The agency did not provide other contractors an opportunity to be
considered for this order because the program manager stated that
the services were unique and highly specialized. Shortly
thereafter, the agency awarded a second order covering another 10
months of work at an estimated cost of $6.7 million as a logical
follow- on to the initial $300,000 order. Finally, the agency
awarded the order included in our review a $7- million order
covering another 11 months of work as a logical follow- on to the
two previous orders. Thus, contrary to FASA, other contractors
were not provided an opportunity to be considered for the work.
OFPP's best practice guidebook suggests that follow- on orders
should not be substantially broader in scope and dollar value than
the original competitive order. Contrary to this guidance, three
of the seven logical follow- on orders were substantially broader
in scope or dollar value than the original orders for which the
agency had provided an opportunity for competition. For example,
one order, awarded under a National Institutes of Health contract,
called for $1.6 million in support for Army communications systems
over 1 year. Although the National Institutes of Health provided
its contractors an opportunity to be considered for this order,
only one contractor chose to submit a proposal. The order we
reviewed, awarded noncompetitively as a logical follow- on to the
$1. 6 million order, provided for $32.1 million in effort over 45
months, or about $8. 5 million annually. The work description for
this follow- on order includes two task areas the original order's
work description does not mention. To accomplish the work under
the follow- on order, the contractor proposed to increase staffing
to a level almost three times that proposed for the original
order. Further, the contractor proposed to increase expenditures
for other direct costs such as supplies and equipment to about $2.
6 million annually compared with about $37,000 under the original
order. Thus, this logical follow- on order was inconsistent with
OFPP's best practice guidance. Few Competing Proposals For 12 of
the 22 orders, agencies provided contractors a fair opportunity to
Were Received When be considered, but they received few competing
proposals. In six cases, a Contractors Were Provided single
proposal was received. While many factors can influence the extent
Opportunities of competition for orders, the presence of an
incumbent contractor appears to have been an important factor for
the orders we reviewed. Ten of these 12 orders were awarded to
fill an ongoing requirement for services. In all but 1 of these 10
cases, all proposals received involved incumbent contractors.
There were no incumbent contractors for the other two orders,
which were to fill new requirements for services. Three proposals
were received for one of these orders, and four were received for
the other. In some cases, it was apparent that incumbent
contractors had an inherent advantage in competing for an order.
For example, the Department of Transportation awarded a $23.7-
million order to support a Navy intelligence command over 5 years
(including options) and asked contractors to submit proposals in
late August to begin work in early October. To provide the
required support, contractors would have needed to station about
40 staff at the Navy installation within days after the order was
awarded. Staff would have required security clearances and
knowledge of the command's information technology system. While
command representatives had been considering options for renewing
their existing support contract for about 6 months, they had not
initiated any contacts to explain their requirements to other
contractors. The representatives indicated that the incumbent
contractor had been performing satisfactorily. Only one proposal
was received: from the incumbent, who already had staff in place
providing similar services. Further, the incumbent had been
supporting the Navy program office for over 20 years and had
developed, integrated, and maintained the information system. The
contracting officer indicated that it would have been difficult
for a competing firm to put together a winning proposal. Another
order, awarded by the General Services Administration, further
illustrates the natural advantages incumbent contractors can have
in competing for work. This order provided for the contractor to
support Army communications systems over 4 years (including
options) at an estimated cost of $149. 2 million. The solicitation
indicated that contractors would be required to provide a hardware
and software laboratory and testing facility equipped for work on
specific makes and models of equipment. Army officials had not
held meetings with other contractors to explain their requirements
or obtain feedback on other contractors' capabilities. The one
contractor that submitted a proposal for this order, the
incumbent, already had a laboratory and testing facility in place.
Agencies sometimes used practices not designed to elicit competing
proposals. For example, one $11.1- million order announced under
the National Institutes of Health contracts covered over 3 years
of support (including options) for an Air Force intelligence
command. The agency asked contractors to submit proposals within 2
days. Command representatives told us that they were satisfied
with the incumbent contractor's performance and that they had not
held meetings to explain their requirements to other contractors.
One proposal was received for the order, again from the incumbent
contractor. According to command representatives, the main purpose
of the order was to obtain the services of a specific employee of
the incumbent contractor who had special expertise. Documents in
the contract files indicate that the command planned to award the
order to the incumbent contractor before the opportunity was
announced. We also noted short time frames for submitting
proposals for other National Institutes of Health orders. The
agency's guidelines now provide that contractors will generally be
provided a minimum of 5 days to submit proposals. In our
discussions with contractor representatives, we gained some
insight into the factors firms consider when deciding whether to
submit a proposal for an order. Contractor representatives
emphasized that the decision entails a business judgment about
their prospects of winning the bid because preparing a proposal is
costly. Contractor representatives cited several factors that can
contribute to a decision not to submit a proposal. For example, a
company may be reluctant to pursue an opportunity if an incumbent
contractor exists, is perceived as having strong qualifications,
and is performing well. If the company does not excel in that
particular type of work, it may be inclined not to submit a
proposal. Other factors that can discourage a company from
submitting a proposal are unreasonably short time frames for
preparing proposals and starting work and selection criteria that
appear to favor incumbent contractors. By contrast, if the company
perceives that its skills and qualifications are superior to the
incumbent's or that the incumbent is a weak performer, it would be
more inclined to pursue an opportunity. Contractor representatives
indicated that lack of agency outreach or market research
activities is another factor that can discourage a company from
submitting a proposal. One outreach activity, for example, is to
hold formal conferences or individual meetings with contractors to
explain the program's requirements and obtain feedback on
contractors' capabilities. Contractor representatives considered
this type of exchange a key step to fostering competition. In
cases where the incumbent contractor has strong qualifications and
is performing well, the prospects of encouraging other contractors
to compete would be limited. Nonetheless, armed with a good
understanding of the program's requirements, a contractor can make
a better informed decision on whether to pursue the bid. Further,
if the contractor decides to pursue the bid, it can more quickly
prepare a responsive, quality proposal and is thus in a better
competitive position. Work Descriptions for Work descriptions for
the large orders we reviewed generally defined tasks Large Orders
Defined broadly. Twenty of the orders were for information
technology services. These orders frequently covered several years
of effort and, because they Tasks Broadly defined the work
broadly, they did not establish a fixed price for the work but
provided for reimbursing contractors' costs. According to program
officials, identifying the information technology services that
will be required in future years involves considerable
uncertainty. FASA requires that orders include a work description
that clearly specifies all tasks to be performed. OFPP, in its
best practice guidebook for multiple- award contracts, stresses
that orders must clearly define the services ordered. In
particular, the guidebook indicates that agencies should not award
large, undefined orders and subsequently issue solesource work
orders for specific tasks. The guidebook also endorses the use of
fixed- price orders where appropriate. According to procurement
regulations, establishing a fixed price for work can be
appropriate when a reasonably definite description of the work can
be developed. Fixed prices also provide an incentive for
contractors to control costs and perform efficiently. Most orders
for services, however, described the work in broad categories, and
in some cases, the agencies issued work orders to define specific
tasks after the order was awarded. For example, the General
Services Administration awarded one order to provide information
technology support services for a Navy detachment over 3 years
(including options). The order stated that the contractor would
provide various types of support technical, project management,
systems engineering, procurement, training, and testing in
connection with the detachment's review of communications
equipment or subsystems for use on Navy ships. The order did not
specify the types of equipment or subsystems that would be
reviewed. The details of the tasks to be performed were to be
negotiated by program officials and the contractor after the order
was awarded. Another order that laid out broad categories of
services was awarded under a National Institutes of Health
contract. This $18.6- million order provided support for a Navy
command's electronic commerce and electronic data interchange
activities over 5 years. The order provided for reimbursing the
contractor's costs. The work description identified numerous
categories of services the contractor would provide. Among the
required services, the work description listed helping to develop
and implement interfaces between systems, analyzing security
requirements and implementing security solutions, analyzing and
developing electronic commerce transaction sets, and operating an
electronic commerce demonstration lab. In addition to these
required services, the order included optional work that the
contractor might provide. These optional services included
evaluating proposed changes to system configurations and
implementing approved configuration changes, preparing briefings
and papers in support of the program, and providing support to
program- related task groups and action teams. When the program
notifies the contractor that specific work is needed, the
contractor is to develop a management plan for the task that
describes the planned technical approach and includes time frame
and resource estimates. According to the program manager, the work
description was designed to encompass all the work that might be
required during the 5- year period. The orders we reviewed
frequently covered multiple years of effort. Program officials
cited the rapid evolution of information technology and the need
to accommodate changes in DOD's program requirements as reasons
why forecasting long- term needs was difficult. Therefore, they
said, work descriptions must be sufficiently flexible to
accommodate the evolution of requirements. We were told that
flexibility is particularly important when orders cover work
required several years into the future. Conclusions Congress has
expressed concerns that agencies could waste taxpayer dollars in
the absence of competition. The National Defense Authorization Act
for Fiscal Year 2000 requires that the procurement regulations be
revised to identify steps agencies should take to ensure that
contractors are afforded a fair opportunity to be considered for
orders and that orders clearly specify all the services or
supplies to be delivered. Competition helps federal agencies
ensure the best value is obtained in awarding contracts. We found
that few competing proposals were received for millions of
dollars' worth of orders we reviewed. Lack of agency outreach can
discourage companies from competing for orders. We also found that
broad work descriptions for task and delivery orders did not
promote the use of fixed- price orders. Recommendations We
recommend that the Administrator of OFPP, as chair of the Federal
Acquisition Regulatory Council, seek to develop and incorporate
guidance to make it clear that agencies should not (1) award
follow- on orders whose scope or costs significantly exceed those
of orders for which contractors were provided an opportunity to be
considered or (2) award large undefined orders and subsequently
issue sole- source work orders for specific tasks and encourage
contracting officers to use fixed- price orders to the maximum
extent practicable. Further, we recommend that the guidance
encourage agencies to conduct more outreach activities when
providing contractors an opportunity to be considered for orders.
Agency Comments OFPP, the National Institutes of Health, the
Department of Transportation, DOD, and the General Services
Administration reviewed a draft of this report. OFPP stated that
it shares the general concerns underlying the recommendations but
is not prepared to endorse specific changes at this time. OFPP
fully agreed that further review of current practices and polices
surrounding the issues raised in the report is warranted to ensure
that customers are enjoying the benefits of multiple- award
contracts. OFPP is looking at current guidance to determine what
additional changes might help agencies in their planning to avoid
situations where initial orders of limited scope lead to
noncompetitive awards of orders of a much larger magnitude. OFPP
is looking at how modular- contracting principles can be better
applied by customers to avoid issuing unnecessarily large orders
and inadequately defined orders. A proposed regulatory change
would emphasize the preference for performance- based statements
of work, which OFPP expects would result in greater use of fixed-
price orders. OFPP shares our concern that effective
communications between customers and multiple- award contract
holders is critical if agencies are to take full advantage of the
highly competitive environment that multipleaward contracts offer
to meet agencies' needs. OFPP stated that it appreciates that
dialogue is necessary to improve communications and to ensure that
requirements and risks are well understood in order to help
contract holders and customers prepare well- defined solutions and
achieve the benefits of competition. OFPP's comments are in
appendix II. The National Institutes of Health concurred with our
recommendations and provided written comments (see app. V). The
Department of Transportation reviewed a draft of this report but
provided no comments. DOD reviewed a draft of this report and
stated that it concurred with two of our three recommendations.
DOD's written comments are in appendix III. DOD and the General
Services Administration expressed concern with one of our
recommendations, as discussed below. The General Services
Administration's written comments are in appendix IV. DOD and the
General Services Administration questioned our recommendation that
guidance be developed to encourage agencies to conduct more
outreach activities when providing contractors an opportunity to
be considered for orders. DOD observed that in view of the
numerous reasons we cite in our report for contractors' decisions
not to submit proposals, government outreach might be of limited
effectiveness. The General Services Administration expressed doubt
that exchanges of information before a solicitation would be a
major factor in contractors' decisions. While we believe it would
be unrealistic to expect any one initiative to ensure multiple
proposals are received for all orders, the contractors we met with
told us that outreach would be helpful in fostering more
competition. Therefore, we believe agencies should conduct more
outreach activities if they want to encourage contractors to
submit competing proposals. As a result, we still believe our
recommendation for greater outreach is appropriate. The General
Services Administration also objected to our draft report title
that characterized competition for orders as limited. In
particular, the General Services Administration does not believe
that competitive offers can be achieved only through multiple
proposals. We acknowledge that the fact that an agency receives
only one proposal does not demonstrate that the proposal is not a
competitive offer. We revised the report title to address the
General Services Administration's concern. Scope and To examine
DOD's placement of large orders under multiple- award, task-
Methodology and delivery- order contracts, we reviewed the
legislative history of provisions relating to multiple- award
contracts and the procurement regulations implementing these
provisions and held discussions with OFPP officials responsible
for monitoring implementation of the provisions. Because no
governmentwide listing of multiple- award contracts for
information technology was maintained, we judgmentally selected
multiple- award contracts for review. The four contract programs
selected are administered by the charter members of the
Governmentwide Agency Contracts Program Managers Council a group
formed to establish standards for and promote more effective
management of governmentwide contracts. The contract programs
selected were the Defense Information Systems Agency's Defense
Enterprise Integration Services II contracts; the Department of
Transportation's Information Technology Omnibus Procurement
contracts; the General Services Administration's 9600' contracts;
and the National Institutes of Health's Chief Information Officer
Solutions and Partners contracts. We examined orders placed under
these contracts to support DOD's activities and awarded between
October 1, 1997, and December 31, 1998, and reviewed all orders
valued at $5 million or more. To assess agency ordering procedures
and determine the extent of competition, we discussed award
procedures for orders with agency officials and reviewed agency
guidance relating to the ordering process. In addition, for each
order reviewed, we examined documentation in the contracting files
to ascertain the extent of competition evident for the order. We
reviewed statements of work to assess whether the work
descriptions clearly specified the tasks to be performed or
supplies to be delivered. We also held discussions with
contracting officials to obtain information about any barriers to
or limitations on competition and about any impediments to clearly
specifying the tasks or supplies ordered. We held discussions with
representatives from program offices acquiring services and
equipment through the orders we reviewed to understand their role
in the award process and obtain their perspective on the issues
being examined. Finally, we held discussions with officials of
selected contractors to obtain their perspectives on barriers to
competition and on how orders specified tasks. We conducted our
review from February 1999 through February 2000 in accordance with
generally accepted government auditing standards. We are sending
copies of this report to Senator John Warner, Chairman, and
Senator Carl Levin, Ranking Minority Member, Senate Armed Services
Committee, and other interested congressional committees. We are
also sending copies of this report to the Honorable William S.
Cohen, Secretary of Defense; the Honorable Donna E. Shalala,
Secretary of Health and Human Services; the Honorable Rodney E.
Slater, Secretary of Transportation; the Honorable David J.
Barram, Administrator of General Services; and the Honorable Jacob
J. Lew, Director, Office of Management and Budget. We will make
copies available to others on request. Please contact me at (202)
512- 4841 if you have any questions concerning this report. Key
contributors to this assignment are listed in appendix VI. Louis
J. Rodrigues Director Defense Acquisitions Issues Appendi Appendi
xes x I Information on Selected Orders Dollars in millions
Incumbent involved in Cost or Work duration winning team b Agency
and contract/ order Order price a fixed price (months) a (yes or
no) Defense Information Systems Agency Defense Enterprise
Integration Services contracts Defense Megacenter Operations $5. 3
Fixed price 12 Yes This order provided for services that encompass
all aspects of technical and operational support for the
Department of Defense (DOD) computer center located in Montgomery,
Alabama. Services included computer system operations and
management, help desk support, specialized training, and special
studies and analyses. DOD Electronic Commerce Program $5. 2 Cost 8
Yes This order provided for services to support development and
fielding of improved electronic commerce and electronic data
interchange systems within DOD. Key efforts included integrating
the Defense Travel System and Defense Finance and Accounting
Service systems into DOD's electronic commerce network.
Distribution Standard System $8. 1 Cost 18 Yes This order provided
for services to support development of a standard management
system for DOD supply depots. These services included designing
and testing essential software changes, providing expertise for
software enhancement, and implementing changes at operational
sites. Global Air Transportation Execution System $14. 0 Cost 14
Yes This order provided for services to continue development of an
improved air transportation management information system. The
effort included systems engineering, software coding, integrating
components, system installation, testing, and training. Global
Decision Support System $6. 4 Cost 12 Yes This order provided for
services to continue modernization of an air transportation
command and control system. These services included defining
hardware and software requirements, developing and integrating
software applications, providing training, and providing system
and software maintenance. Maintenance Planning and Execution
System $7. 0 Cost 11 Yes This order provided for services to
support development and fielding of a standard management system
for DOD maintenance depots. These services included completing
design and development of an updated version of the system,
installing the system at selected locations, and providing ongoing
support for installed systems. Department of Transportation
Information Technology Omnibus Procurement contracts Defense
Computer Forensic Lab Support $6. 4 Cost 41 No This order provided
for services to support operation of a laboratory that analyzes
computer- based information gathered during criminal
investigations. The scope included services to support the
functions of computer systems administrators, forensic examiners,
evidence custodians, database analysts, and office managers. Army
Defense Message System $30. 5 Cost 59 Yes This order provided for
technical support services for all aspects of design, testing, and
implementation of the Defense Message System at Army
installations. Efforts included conducting site surveys,
developing site implementation plans, installing and integrating
components, and conducting training. Atlantic Command On- line
System $23. 7 Cost 60 Yes This order provided for systems
management and information technology support services for the
Navy Atlantic Command and Atlantic Intelligence Command. These
services included systems engineering, architecture planning,
information technology evaluation, and training support. Continued
Dollars in millions Incumbent involved in Cost or Work duration
winning team b Agency and contract/ order Order price a fixed
price (months) a (yes or no) Joint Strike Fighter Program Office
Local Area Network Support $17. 2 Cost 60 Yes This order provided
for services to support all aspects of design, acquisition, and
implementation of program office information systems. Specific
services included administering the local area network, providing
a user help desk, supporting Internet and e- mail services, and
providing infrastructure support. Transportation Coordinators'
Automated Information for Movements System $35. 9 Cost 60 Yes This
order provided for services to continue developing a standard
transportation management system for DOD fighting units. The
services included software engineering, application development,
integrated logistics support, and testing. General Services
Administration 9600 contracts Air Mobility Command Command and
Control Systems $26. 1 Cost 60 Yes This order provided for
services and related hardware and software to support a range of
command and control systems. The services included strategic
program management, software development and maintenance, database
administration, testing, training, and customer support. Joint
Professional Military Education Program $5. 5 Fixed price/ cost 24
No This order provided for services to design and implement
upgraded training tools for the Armed Forces Staff College. These
services included planning for curriculum enrichment, analyzing
requirements and developing designs for training tools, and
implementing a final system design. Naval In- service Engineering
Detachment $51. 3 Cost 36 Yes This order provided for services to
support the design and integration of communications systems
aboard the Navy fleet. These services included support for project
management, technical reviews, training, system engineering,
system integration, test and evaluation, and procurement. Reserve
Component Automation System $18. 2 Cost 60 Yes This order provided
for services to help manage development of an automated system to
support operational and administrative tasks for the Army National
Guard and Reserves. These services included support for functions
such as independent evaluation, strategic planning, systems
engineering, and project management. Worldwide Technical Control
Improvement Program $149. 2 Cost 48 Yes This order provided for
services to help the Army Communications- Electronics Command
upgrade control facilities for the Army's longhaul communications
systems. These services included support for functions such as
procurement and production, equipment installation, and training.
National Institutes of Health Chief Information Officer- Solutions
and Partners contracts Air Intelligence Command Support $11. 1
Cost 44 Yes This order provided for services to help maintain and
upgrade computer network infrastructure for the Command's 480th
Air Intelligence Group. These services included engineering
support for the enhancement of several systems, hardware
installation, network operations support, and year 2000
remediation support. Defense Megacenter Central Processing Units
$65. 2 Fixed price 8 Yes This order provided for central
processing units to upgrade data processing capabilities at
various DOD computer centers. Continued from Previous Page Dollars
in millions Incumbent involved in Cost or Work duration winning
team b Agency and contract/ order Order price a fixed price
(months) a (yes or no) Defense Megacenter Disk Drives $10. 7 Fixed
price 6 Yes This order provided for disk drive units to upgrade
data processing capabilities at various DOD computer centers.
Digital Communications Satellite Subsystem $32. 1 Cost 45 Yes This
order provided services to support equipment that provides signal
processing and jamming protection for the Defense Satellite
Communications System. These services included analyzing and
determining requirements, conducting research and evaluations, and
developing site engineering plans. Military Sealift Command
Electronic Commerce $18. 6 Cost 60 Yes This order provided
services to support the Command's electronic commerce initiatives.
These services included helping develop and implement interfaces
between systems, analyzing security requirements, operating an
electronic commerce demonstration lab, and preparing briefing
papers in support of the program. Portal Shield System Support $5.
3 Cost 23 Yes This order provided services to support development
of an automated system to detect biological warfare agents. These
services included production engineering and evaluation; systems
engineering support; and assembly, integration, and test of
initial production units of the system. Continued from Previous
Page a Order price and work duration include effort under options
the government may or may not exercise. b In some cases, the
winning contractor was the incumbent contractor or a subcontractor
of the incumbent. In other cases, the winning contractor indicated
that it planned to award a subcontract to the incumbent contractor
or to one of the incumbent's key subcontractors. Comments From the
Office of Federal Appendi x II Procurement Policy Appendi x II I
Comments From the Department of Defense ap3p1 See comment 1. See
p. 11. See comment 2. See comment 3. See comment 4. The following
are GAO's comments on DOD's letter, dated February 15, 2000. GAO
Comments 1. The Federal Acquisition Streamlining Act (FASA)
requires that agencies placing orders under multiple- award
contracts provide each contractor an opportunity to be considered
unless one of the statutory exceptions applies. DOD stated that it
might be appropriate for the ordering office to announce its
intention to award to one of the multiple- award contract holders.
Office of Management and Budget officials concluded that the
practice of identifying a preferred source, as announcing
intentions to award to a contractor would do, discourages
competition and deprives the government of the benefits of
efficiency and innovation that competition provides. Further,
federal procurement regulations were revised to prohibit agencies
from designating preferred sources. 2. Although the governmentwide
policies relating to multiple- award contracts have been in place
for over 4 years, additional training in these policies would no
doubt produce benefits. However, we believe that the additional
guidance we recommend is needed to foster increased competition
for orders. 3. It is not clear to us whether the Civilian
Personnel Management Service intends to endorse expanded use of
time and materials contracts despite the recognition that this
contracting method is generally not advantageous to the
government. 4. Our concern was that a contractor might be denied
the opportunity to compete for a large follow- on order because
the contractor had decided not to submit a proposal on an original
order with a narrow scope or insignificant dollar value. The
Navy's suggestion represents one option for alleviating this
concern. However, we believe the original orders would have to
provide enough details of the scope and anticipated dollar value
of future work to allow sound contractor decisions on whether to
compete for the work. In view of program officials' comments about
the difficulty of forecasting long- term information technology
needs, it is likely that few details of the scope and anticipated
dollar value of future work could be provided. Comments From the
General Services Appendi x V I Administration See p. 8. See
comment 1. See p. 12. See comment 2. See comment 3. The following
are GAO's comments on the General Services Administration's
letter, dated February 22, 2000. GAO Comments 1. As the General
Services Administration points out, agencies are not required to
structure a solicitation so as to neutralize the incumbent's
advantage. We did not suggest that agencies should neutralize the
incumbent's advantage. We stated that agencies could encourage
competition for some orders by helping prospective contractors
understand the agency's requirements. However, for the orders
reviewed, the presence of an incumbent contractor appeared to be
an important factor influencing the extent of competition. As we
note in our report, 10 of the 12 orders where contractors were
provided an opportunity to be considered were issued to fill
ongoing requirements for services. In all but 1 of these 10 cases,
all proposals received involved incumbent contractors. While
incumbency presents significant advantages, a number of
contractors told us that market outreach activities promote
competition and allow firms to prepare better proposals. 2. The
guidance the General Services Administration cites discusses the
relative importance of cost or price compared with other factors
in selecting a source and does not address the desirability of
establishing a fixed price. We recognize that it is sometimes not
appropriate to establish a fixed price for work, and we recommend
that guidance encourage the use of fixed prices where practicable.
3. According to the contract documents for this order, when Navy
officials notify the contractor of a new requirement, the
contractor is to prepare a Program Master Plan for the
requirement. This Program Master Plan is to include the scope and
technical requirements of the project, the place and period of
performance, milestones and deliverables for the project,
personnel and other direct costs, and any data or materials the
government will provide. The contractor is to provide a draft Plan
to Navy officials for review and concurrence before preparing a
final version of the Plan. We believe the report accurately
characterizes the procedures for defining new tasks under this
order. Comments From the National Institutes of Appendi x V Health
Appendi x VI GAO Contacts and Staff Acknowledgments GAO Contacts
David E. Cooper (202) 512- 4841 Ralph Dawn (202) 512- 4544
Acknowledgments In addition to those named above, Ken Graffam,
Charles Malphurs, Monty Peters, John Van Schaik, and William T.
Woods made key contributions to this report. (707392) Lett er GAO
United States General Accounting Office Page 1 GAO/NSIAD-00-56
Contract Management Contents Letter 3 Appendixes Appendix I:
Information on Selected Orders 18 Appendix II: Comments From the
Office of Federal Procurement Policy 21 Appendix III: Comments
From the Department of Defense 24 Appendix IV: Comments From the
General Services Administration 28 Appendix V: Comments From the
National Institutes of Health 33 Appendix VI: GAO Contacts and
Staff Acknowledgments 35 Tables Table 1: Competing Proposals
Received 8 Abbreviations DOD Department of Defense FASA Federal
Acquisition Streamlining Act OFPP Office of Federal Procurement
Policy Page 2 GAO/NSIAD-00-56 Contract Management Page 3
GAO/NSIAD-00-56 Contract Management United States General
Accounting Office Washington, D. C. 20548 Page 3 GAO/NSIAD-00-56
Contract Management B-281493 Page 4 GAO/NSIAD-00-56 Contract
Management B-281493 Page 5 GAO/NSIAD-00-56 Contract Management B-
281493 Page 6 GAO/NSIAD-00-56 Contract Management B-281493 Page 7
GAO/NSIAD-00-56 Contract Management B-281493 Page 8 GAO/NSIAD-00-
56 Contract Management B-281493 Page 9 GAO/NSIAD-00-56 Contract
Management B-281493 Page 10 GAO/NSIAD-00-56 Contract Management B-
281493 Page 11 GAO/NSIAD-00-56 Contract Management B-281493 Page
12 GAO/NSIAD-00-56 Contract Management B-281493 Page 13 GAO/NSIAD-
00-56 Contract Management B-281493 Page 14 GAO/NSIAD-00-56
Contract Management B-281493 Page 15 GAO/NSIAD-00-56 Contract
Management B-281493 Page 16 GAO/NSIAD-00-56 Contract Management B-
281493 Page 17 GAO/NSIAD-00-56 Contract Management Page 18
GAO/NSIAD-00-56 Contract Management Appendix I Appendix I
Information on Selected Orders Page 19 GAO/NSIAD-00-56 Contract
Management Appendix I Information on Selected Orders Page 20
GAO/NSIAD-00-56 Contract Management Page 21 GAO/NSIAD-00-56
Contract Management Appendix II Appendix II Comments From the
Office of Federal Procurement Policy Page 22 GAO/NSIAD-00-56
Contract Management Appendix II Comments From the Office of
Federal Procurement Policy Page 23 GAO/NSIAD-00-56 Contract
Management Page 24 GAO/NSIAD-00-56 Contract Management Appendix
III Appendix III Comments From the Department of Defense Page 25
GAO/NSIAD-00-56 Contract Management Appendix III Comments From the
Department of Defense Page 26 GAO/NSIAD-00-56 Contract Management
Appendix III Comments From the Department of Defense Page 27
GAO/NSIAD-00-56 Contract Management Page 28 GAO/NSIAD-00-56
Contract Management Appendix IV Appendix IV Comments From the
General Services Administration Page 29 GAO/NSIAD-00-56 Contract
Management Appendix IV Comments From the General Services
Administration Page 30 GAO/NSIAD-00-56 Contract Management
Appendix IV Comments From the General Services Administration Page
31 GAO/NSIAD-00-56 Contract Management Appendix IV Comments From
the General Services Administration Page 32 GAO/NSIAD-00-56
Contract Management Page 33 GAO/NSIAD-00-56 Contract Management
Appendix V Appendix V Comments From the National Institutes of
Health Page 34 GAO/NSIAD-00-56 Contract Management Page 35
GAO/NSIAD-00-56 Contract Management Appendix VI Ordering
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