Federal agencies need to implement consistent reporting and improve data quality when they create ratings for the contractors that the agencies do business with, according to a new Government Accountability Office (GAO) report that finds government-wide shortfalls in meeting existing guidance and requirements.
The General Services Administration’s (GSA) Federal Awardee Performance and Integrity Information System (FAPIIS) contractor database produces score cards on prospective contractors’ performance, business ethics, and termination information.
In looking at how Federal agencies were providing information to GSA for the database over a five-year period, GAO found that 335 contract terminations and 52 administrative agreements weren’t reported in FAPIIS.
FAPISS system data is required to be reviewed to determine responsibility before awarding any contract over the simplified acquisition threshold which is usually set at $250,000.
“To be determined responsible, a prospective contractor must meet certain qualifications, such as having a satisfactory performance record and a satisfactory record of integrity and business ethics, among others,” said GAO, noting that the final determination of a contractor’s responsibility is “within the broad discretion of the contracting officer.”
GAO found that eight out of 24 agencies that reported Federal contract terminations in the Federal Procurement Data System (FPDS) entirely failed to do the same in FAPIIS – with only one agency reporting matching termination records between both systems.
GAO also found that some agencies reported administrative agreements to the Interagency Suspension and Debarment Committee’s (ISDC) – acting as a forum to coordinate suspension, debarment, and policy – but not to FAPIIS. In total, GAO found 52 more administrative agreements filed with the ISDC than FAPIIS.
Agencies that had reporting shortfalls include the Department of Defense (DoD), GSA, and the departments of Energy (DoE), Health and Human Services (HHS), and Veterans Affairs (VA). These agencies cited to GAO limited insight into why there was no reporting, referred to gaps in guidance and limited awareness of reporting requirements, and mentioned other various reasons for not reporting terminations.
GAO made four recommendations to improve reporting, including that the Office of Management and Budget (OMB) reiterate integrity reporting requirements.
A 2013 OMB memorandum provides guidance on contractor performance data in FAPIIS, but agencies aren’t required to use all available resources for data verification. OMB said it’s aware of data quality concerns and is considering updates to its guidance, but didn’t provide a specific timeline, according to GAO.
“The extent of overall underreporting in government-wide integrity records and the fact that OMB issued relevant guidance over a decade ago indicate that there is a need for OMB to reiterate reporting requirements and identify available resources to corroborate integrity information,” said GAO. “Doing so would help ensure that agency personnel have the guidance needed to comprehensively report and verify the accuracy of integrity information.”
Additional recommendations provided by GAO include that the Department of Defense and GSA “take steps to ensure their personnel have awareness of integrity reporting requirements.” Those agencies agreed with the recommendations.
