Concept of Operations for the GSA Office of the Procurement … · GSA acquisition processes, and;...
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CONCEPT OF OPERATIONS FOR THE GENERAL SERVICES ADMINISTRATION OFFICE OF THE PROCUREMENT OMBUDSMAN JUNE 2016
Transcript of Concept of Operations for the GSA Office of the Procurement … · GSA acquisition processes, and;...
CONCEPT OF OPERATIONS FOR THE GENERAL SERVICES ADMINISTRATION
OFFICE OF THE PROCUREMENT OMBUDSMAN
JUNE 2016
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Revision History
Date Version Change Description Author
6/21/2016 V1 Minor edits throughout document M. Gary
7/19/2016 V1 Edits to 2.2.4 M. Gary
08/12/2016 V2 Edit of document based on input from AV T. Halsell
09/02/2016 V2 Include MV changes and update stakeholder diagram
T. Halsell
9/12/2016 V3 Edits to 4.0 and other parts M. Gary
01/18/2017 V4 Edits, re-order of sections, consolidate comments
M.Gary
1/27/2017 Edits to 5.1 M.Gary
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Contents 1. Executive Summary .................................................................................................................... 1
2. Introduction ................................................................................................................................. 2
2.1 Overview of the Concept of Operations ............................................................................... 2
2.2 Authorities............................................................................................................................. 2
2.2.1 Legal and Regulatory Authorities .................................................................................. 2
2.2.2 Authority to Establish the Office of the Procurement Ombudsman .............................. 2
2.2.3 Authority of the Ombudsman ........................................................................................ 3
2.2.4 Scope .............................................................................................................................. 3
2.2.5 Stakeholders ................................................................................................................... 5
3.0 Current State ............................................................................................................................. 7
3.1 Environment .......................................................................................................................... 7
3.2 GSA Acquisition (FAS, PBS, TTS and OAS) ...................................................................... 7
3.3 GSA Acquisition Management ............................................................................................. 8
3.3.1 Office of Government-wide Policy ................................................................................ 8
3.3.2 Office of Acquisition Policy .......................................................................................... 9
4.0 Capability Gaps ....................................................................................................................... 11
4.1 Contributing Factors ........................................................................................................... 12
5.0 Future State ............................................................................................................................. 13
5.1 Future State Mission, Vision, Objectives, Strategy, and Values ........................................ 13
5.2 Proposed Organizational Structure ..................................................................................... 15
5.3 Assumptions ........................................................................................................................ 17
5.4 Constraints .......................................................................................................................... 17
6.0 Future Service Delivery Model ............................................................................................... 19
6.1 Future Service Delivery Strategies ..................................................................................... 19
6.1.1 Communication ............................................................................................................ 20
6.1.2 Training ........................................................................................................................ 24
6.1.3 Policy, Process and Complaint Resolution .................................................................. 24
6.1.4 Acquisition Process Improvement ............................................................................... 26
6.2 Future Operational Approach ............................................................................................. 26
6.3 Future Benefits .................................................................................................................... 27
6.4 Relationships and Dependencies ......................................................................................... 29
7.0 Risks and Mitigation ........................................................................................................... 30
8.0 How to contact the Office of the Procurement Ombudsman .............................................. 31
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List of Appendices ....................................................................................................................... 32
Appendix A: Strengths, Weaknesses & Opportunities ........................................................... 33
Appendix B: OPO Required System Access ............................................................................. 39
Appendix C: Industry Coordinator Description ...................................................................... 40
Appendix D: Industry Liaison Description .............................................................................. 41
Appendix E; Industry Associations ........................................................................................... 42
Appendix F; Abbreviations ........................................................................................................ 43
Appendix G; Development Team .............................................................................................. 44
Appendix H: Approval ............................................................................................................... 45
1. Executive Summary
GSA commits substantial financial and manpower resources to procurement activities to accomplish its mission to deliver the best value in real estate, acquisition, and technology services to government and the American people. In FY15, GSA actively managed a procurement budget of $9 billion through 148,125 acquisition transactions.1 FY16 transaction projections suggest not only increased volume, but increased complexity, due to the growing number of vendors eligible for preferential consideration. This volume of activity places GSA in a position to offer numerous business opportunities to the private sector across the board, including small businesses, start-ups, and those not familiar with doing business in the government market space.
While GSA acquisition processes are defined in law and policy, overall success is based on a coordinated partnership between GSA and the vendors who are seeking to sell their products and services to the government. When vendors and the acquisition workforce follow the prescribed guidelines, acquisition processes are generally successful. However, recent GSA reviews and industry surveys indicate GSA processes are not always well communicated or understood.2,3 In some cases, GSA processes are inconsistent or unnecessarily complex, causing confusion for both vendors and the GSA acquisition workforce. This suggests improved communication, training and early intervention could alleviate many of these problems.
To prepare for the future of the acquisition environment, GSA created the Office of the Procurement Ombudsman (OPO). The OPO is based around a comprehensive strategy designed to a) improve vendor and GSA acquisition workforce relationships; b) provide an informal forum for vendors and vendor associations to voice their concerns of unfair practices in GSA’s acquisition process; c) intercede early in the acquisition process to resolve disputes before they escalate to formal complaints; d) collaborate on formal industry feedback collection processes to identify training needs, to assess marketplace trends and make recommendations to improve GSA acquisition processes, and; e) share lessons learned, promote best practices, and improve acquisition policies as part of the greater government-wide acquisition policy mission.
To accomplish these goals, the office will initially enlist the support and assistance of resources provided by GSA acquisition service organizations. As workload increases, the office will be staffed with the appropriate level of resources to facilitate accomplishment of its mission, goals and objectives. The anchoring documents that support and delineate the mission and governing structure of OPO are the:
• Concept of Operations • Program Development Plan • Industry Communications Plan
1 Federal Procurement Data System. 2 Industry Acquisition Survey, GSA Office of Citizen Services, Innovation and Technology. 3 OGP Acquisition 360 Survey.
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2. Introduction
This document presents the Concept of Operations for the Office of the GSA Procurement Ombudsman (OPO). The Ombudsman is established under the authority and auspices of the GSA Chief Acquisition Officer and the GSA Senior Procurement Executive. The office is housed in the Office of Acquisition Policy within the Office of Government-wide Policy.
2.1 OVERVIEW OF THE CONCEPT OF OPERATIONS
The purpose of the Concept of Operations (Con-Ops) is to provide guidance for the structure (governance), management and operations of OPO, taking into consideration the mission and vision of GSA, its stakeholders and its influence on the federal acquisition process. Specific objectives of the Con-Ops are as follows:
● Present the rationale and the drivers behind establishment of OPO and its program, including the key benefits to be realized.
● Describe the environment within which the program will operate, including identification of key internal and external stakeholders.
● Define the overarching governance structure that will engage and connect stakeholders from across the government and create a manageable and sustainable framework for long-term success, including the mission, vision, objectives and metrics for tracking program effectiveness.
● Outline the roles and responsibilities of key program participants involved in developing, implementing and managing the ombudsman program.
● Describe the process that program participants will follow in developing, implementing and managing vendor engagement strategies and process improvement initiatives.
This Con-Ops is a working document that will be updated periodically over the lifecycle of the program as new priorities, policies and requirements emerge.
2.2 AUTHORITIES
2.2.1 Legal and Regulatory Authorities
The Federal Acquisition Regulation provides the legal basis for an Ombudsman.
2.2.2 Authority to Establish the Office of the Procurement Ombudsman
The GSA Procurement Ombudsman is established through the authority of the GSA Senior Procurement Executive (SPE). The position, role and jurisdiction are established pursuant to written agency policy governing the authority of the SPE. Pursuant to FAR subpart 16.5, GSA established a Task and Delivery Order Ombudsmen whose responsibility is limited to only addressing “Fair Opportunity” for consideration of award of task and delivery orders.
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The Office of the Procurement Ombudsman is a sub-organization within the Office of Acquisition Policy. Ombudsman duties are acquisition core requirements. Staffing appointment decisions (establishment of positions) are within the discretion of the GSA SPE.
2.2.3 Authority of the Ombudsman
The Ombudsman will have the authority to:
● Receive inquiries and questions ● Exercise discretion to accept or decline to act on a complaint or question ● Act on personal initiative to prevent problems and address issues systematically
within assigned jurisdictions ● Aid in the resolution of complaints or problems ● Gather information and enlist full cooperation of GSA acquisition programs ● Resolve issues at the appropriate levels within GSA ● Function by such means as the following:
• Conducting inquiries • Reviewing issues and report findings • Developing, evaluating, and discussing options • Facilitating, mediating, and providing conciliation services • Making recommendations • Identifying patterns and trends, and potential systemic issues • Educating • Issuing periodic reports
● Participate in litigation to enforce or protect the authority of the OPO as established in formal policy, the standards for the Establishment and Operation of Ombudsmen Offices, or required by law.
2.2.4 Scope
GSA has several mechanisms for addressing and responding to issues raised by vendors and industry associations. The Ombudsman will not replace those mechanisms, but will support them to better serve customers and stakeholders.
The Ombudsman will not:
● Address matters already in litigation or under formal dispute, protest or investigation ● Delay any statutory, regulatory, or other GSA deadlines ● Make decisions, legal or otherwise, for GSA ● Serve as a formal office of legal notice for GSA ● Address internal human resource matters.
The Ombudsman will address industry and vendor complaints, issues, and recommendations, along with identifying inconsistent or harmful policies and practices, and recommend solutions to stakeholders, where appropriate.
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The Ombudsman will also provide recommendations for standardization, centralization and automation to improve efficiency. The Ombudsman will not manage acquisition programs but will promote improvement initiatives, where appropriate. The Ombudsman will also rely on Industry Coordinators, Industry Liaisons and Supplier Relationship Managers to provide the required support for process improvement recommendations and issue resolution, where appropriate.
The Ombudsman will intervene in specific acquisition situations to de-escalate and facilitate resolution of complaints. The Ombudsman will work directly with acquisition practitioners, the Office of General Counsel and vendors to gather evidence to provide impartial solutions to issues that arise. It is expected that vendors and all GSA acquisition practitioners will provide full and immediate disclosure of relevant data and information, without delay so that the Ombudsman can act quickly and efficiently to resolve complaints. The process for Ombudsman intervention to resolve specific vendor issues/complaints will be codified and fully coordinated with the appropriate stakeholders.
The Ombudsman has a range of tools that assist with resolving an issue such as:
• Discussion with internal stakeholders • Facilitation of meetings between stakeholders • Shuttle diplomacy • Highlighting systemic issues • Issuing recommendations to address an individual or systemic issue.
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GSA Stakeholders
Industry Stakeholders
External Government Agency k h ld
2.2.5 Stakeholders
Stakeholders are categorized into three distinct groups (Figure 2-1). Internal stakeholders include all the dedicated procurement organizations and organizations that routinely support procurement processes within GSA. External government stakeholders include all federal agencies engaged in acquisition processes as well as specific agencies that support acquisition processes. Industry stakeholders are highlighted in a separate non-government category.
Figure 2-1. Major Stakeholder Groups
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The OPO will work closely with GSA acquisition practitioners and agency partner stakeholders to highlight the inherent benefits of working in partnership with industry.
2.2.5.1 GSA STAKEHOLDERS
The OPO will work with representative stakeholders from each of the services (FAS, PBS and TTS) to resolve policy issues, standardize processes and improve industry procurement opportunities. The OPO will collaborate with stakeholders from the Office of Acquisition Policy and the Office of Administrative Services to centralize, coordinate, and align GSA procurement activities, where possible. The OPO will rely on the Office of Communications and Marketing stakeholders to provide support and expertise to develop effective industry marketing and outreach campaigns. The OPO will coordinate with GSA Office of Small Business Utilization to ensure industry stakeholders can leverage minority, veteran, HUBZone, and women-owned opportunities. Finally, OPO will ensure coordination with the Office of General Counsel and the Office of the Inspector General, when appropriate.
2.2.5.2 EXTERNAL GOVERNMENT AGENCY STAKEHOLDERS
The OPO will maintain working relationships with external federal agency stakeholders through a variety of forums including formal interagency working groups, agency-to-agency policy discussions, joint outreach and training events. The OPO will also maintain an active and open dialogue with the Office of Federal Procurement Policy and the US Small Business Administration to ensure alignment of GSA improvement initiatives.
2.2.5.3 INDUSTRY STAKEHOLDERS
The OPO will collaborate with industry groups to receive, prioritize and implement industry-wide improvement recommendations. The OPO will also work with individual industry stakeholders to provide advice and process complaints, when requested.
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3.0 Current State
This section provides an overview of the current GSA procurement landscape and describes all GSA organizations that execute or support procurement activities with industry. It provides a baseline of all current GSA acquisition activities. The level of support these organizations currently provide to resolve vendor issues is highlighted to reveal gaps and opportunities for ombudsman intervention and process improvement.
3.1 ENVIRONMENT
GSA influences the management of $500 billion in federal assets, including 9,600 government-owned or leased buildings and 205,000 vehicles on an annual basis.4 In FY15, GSA actively managed a procurement budget of $9 billion through 148,125 acquisition transactions.5 This volume of activity presents GSA with numerous challenges to provide business opportunities for suppliers, including small businesses, start-ups, and businesses new to the Federal market space.
GSA has highly acclaimed and well respected acquisition processes with a long tradition of successfully fulfilling government requirements. GSA procurement processes are well defined and deeply rooted in law and policy. Vendors who successfully navigate these processes, laws, and policies are generally successful in the Federal marketplace. However, recent industry feedback suggests that agencies can improve vendor performance, increase competition and improve acquisition outcomes by providing vendors with increased access to information and early and consistent engagement in the acquisition process.
GSA does not currently have any informal means to absorb industry feedback or review industry recommendations for acquisition policy or process improvements. In addition, GSA lacks an informal intervention process to de-escalate disputes.
3.2 GSA ACQUISITION (FAS, PBS, TTS AND OAS)
GSA manages procurement programs through the Federal Acquisition Service (FAS), the Public Buildings Service (PBS), the Technology Transformation Service (TTS) and the Office of Administrative Services (OAS). Each GSA Service manages an acquisition workforce and employs acquisition processes that are streamlined to meet unique Service needs.
Service Current Capabilities Federal Acquisition Service (FAS)
As the leading source of government acquisition solutions, FAS has extensive, dedicated acquisition expertise. It also has strong outreach programs with industry and provides varying levels of assistance to address industry concerns. However, some FAS programs are not integrated or optimized across GSA, and could be enlarged and extended to other agencies. FAS conducts Contractor Assistance Visits to educate vendors on GSA’s contract management practices and ensure compliance. Its Industry Operations Analysts (IOAs) record and report vendor performance as part of these visits. Although the visits provide vendors with performance feedback, they are not intended to be an impartial review or external source for vendors to seek policy or process improvements or request review of specific complaints.6
4 Federal Procurement Data System. 5 Federal Procurement Data System. 6 GSA InSite Webpage.
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Service Current Capabilities Even though FAS provides strong leadership in its dealings with vendors and industry, there is a gap in external agents or representatives to provide informal and impartial review of complaints; it also lacks any centralized process to de-escalate vendor complaints. Finally, FAS does not have a feedback mechanism to gauge improve processes outside of PBS. In many cases, it implements superior solutions but no agent or activity is available to monitor the solutions to determine their applicability to other GSA acquisition organizations or the potential for government-wide application. The GSA Procurement Ombudsman will fill this gap.
Public Buildings Service (PBS)
PBS has modest vendor outreach and assistance programs, but they are not coordinated with FAS or other GSA organizations. In addition, PBS does not have an external agent or representative to provide informal and impartial review of complaints. Nor does PBS have a centralized process to de-escalate vendor complaints once initiated. Finally, PBS does not have any feedback mechanisms to gauge improve processes outside of PBS. In many cases, PBS implements superior complaint solutions but there is no agent or activity monitoring these solutions to determine applicability to other GSA acquisition organizations or the potential for government-wide implementation.7 The GSA Procurement Ombudsman will fill this gap.
Technology Transformation Service (TTS)
The Technology Transformation Service (TTS) was recently created to help government agencies build, buy and share user-centered and emerging technology solutions. TTS combines the Office of Citizen Services and Innovative Technologies and the 18F organization. TTS will have an acquisition division and will manage an acquisition workforce to include the issuance of warrants and certifications.8 TTS will not have any informal support services to de-escalate complaints. The GSA Procurement Ombudsman will fill this gap.
Office of Administrative Services (OAS)
OAS is a staff office that provides GSA and industry access to acquisition information and reference materials through the Internal Acquisition Division. The Division actively manages acquisitions and acquisition issues through their Acquisition Operations Branch; acquisition policy through their Acquisition Policy Branch; and they manage the acquisition workforce. They also provide COR training. OAS does not have an external agent or representative to provide informal and impartial review of complaints. Nor do they have any formal process to de-escalate vendor complaints once they are initiated.9 The GSA Procurement Ombudsman will fill this gap.
3.3 GSA ACQUISITION MANAGEMENT
GSA provides centralized acquisition policy and management services through the Office of Government-wide policy, which includes several supporting organizations described below.
3.3.1 Office of Government-wide Policy
Overarching policy for management of procurement programs lies with the Office of Government-wide Policy (OGP). OGP is responsible for establishing procurement policy in the areas of personal and real property, travel and transportation, information technology, regulatory information, and use of federal advisory committees. It ensures government policies encourage federal agencies to utilize the most cost effective management practices for the conduct of their specific programs. It also promotes involvement of external federal agencies, private sector, interested parties, and other stakeholders from the onset of policy formulation to ensure “buy-in” and early adoption from policy customers.
7 GSA InSite Webpage. 8 GSA InSite Webpage. 9 GSA InSite Webpage.
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The OGP carries out its responsibilities by (1) incorporating the requirements of federal laws, Executive Orders, and other regulatory guidance into policies and guidelines; (2) facilitating government-wide reform to provide federal managers with business-like incentives and tools, and the flexibility to prudently manage their assets; and (3) identifying, evaluating, and promoting best practices to improve efficiency of management processes.10
The OGP specifically exercises its procurement policies through the Office of Acquisition Policy. The Chief Acquisition Officer (CAO) oversees the Office of Acquisition Policy (OAP) and reports directly to the GSA Administrator. Together, the CAO and SPE oversee all OAP activities, ensuring GSA and government-wide acquisition policies are optimized.
3.3.2 Office of Acquisition Policy
OAP provides centralized acquisition guidance to all GSA acquisition activities (Figure 3-1). In their government-wide role, OAP strives to strengthen Federal policies to help agencies optimize acquisition solutions. OAP collaborates with the Department of Defense and the National Aeronautics and Space Administration (NASA) to introduce government-wide changes to the Federal Acquisition Regulation (FAR) through its leadership on the Federal Acquisition Regulatory Council.11.
Figure 3-1. Office of Acquisition Policy Organizational Structure.
10 GSA InSite Webpage. 11 GSA InSite Webpage.
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The Office of General Services Acquisition Policy, Integrity, and Workforce (API&W) develops acquisition policy and oversees GSA-wide acquisition matters, including policy development; compliance management; remediation (suspension, debarment, and complaint agency level protest management); and workforce management.12
The Office of Government-wide Acquisition Policy (OGAP) focuses on improving government-wide acquisition policies and oversees federal agency acquisition activities to ensure compliance and uniformity in the application of laws, regulations and policies. It also provides transparency into the regulatory programs of all federal agencies.13
The Federal Acquisition Institute (FAI) provides acquisition-related training and professional development for civilian agency acquisition personnel.
12 GSA InSite Webpage. 13 GSA InSite Webpage.
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4.0 Capability Gaps
GSA currently experiences a series of gaps in their capability to deliver the desired level of industry engagement. While procurement processes may be clear in law, they are not always understood or followed by the acquisition workforce or vendor representatives. This section provides a summary of GSA acquisition capability gaps that are impacting vendor performance and access to GSA procurement opportunities. These gaps provide a baseline for development of GSA future state acquisition processes that will include active OPO training, communication, intervention and leadership. Gaps were derived from an overall assessment of current state capabilities described in section 3 above. It also includes input received from various industry sources. These Gaps represent opportunities where OPO can provide value to GSA.
Current gaps that can be eliminated through ombudsman intervention:
• Establishment of a centralized or documented process to informally raise awareness of procurement issues or exchange information with vendor communities.
• Establishment of a centralized means to de-escalate disputes and resolve issues through impartial and informal intervention; and standardized entry portal for vendors or GSA acquisition practitioners to request informal and impartial intervention in disputes.
o Issues that could be resolved informally are often deferred, resulting in unnecessary delays in remediation and absorbing time and expertise that could be allocated to other priorities; it also degrades vendor service delivery to GSA customers because vendors cannot deliver until contract acquisition issues are resolved.
• Establishment of a disinterested third party for examining and reviewing procurement issues.
o In many cases, vendor communities request process changes and relief from individual GSA offices, but no centralized GSA organization exists to collect and review these proposals. Individual offices provide vendor guidance that is often inconsistent and not synchronized between organizations. Although GSA acquisition leaders would like these proposals to be corporately reviewed, no office or organization currently provides that capability.
• Establishment of a mechanism to inform senior leadership of inconsistencies in acquisition processes and discover standardization issues.
• Establishment of a centralized reporting mechanism to provide or evaluate acquisition process performance metrics across GSA.
o At present, individual offices collect and review some metrics within their areas of responsibility.
• Establishment of a consistent method to capture and analyze the key information that would enable the identification of detrimental events.
o In the absence of this ability, GSA is impeded from fully capturing root causes of issues, reengineer processes, and adequately training and communicating critical information to the acquisition workforce and vendor community.
Capability gaps can have significant negative consequences for both GSA and the vendor community. Immediate consequences include unnecessary delays in the procurement process,
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increases in inquiries, complaints and protests, and lack of confidence in the procurement process, in general. The impact of these inefficiencies can mean increased costs to vendors and may impede GSA’s ability to obtain best value solutions for its customers.
4.1 CONTRIBUTING FACTORS
There are several factors that contribute to these gaps. Over all, GSA’s procurement workload continues to increase annually, exacerbating demands for improved support. Added to the increase in volume is the increased number and types of small business concerns (e.g., women-owned, veteran owned, service disabled veteran owned, certified disadvantaged, certified 8(a), and HUBZone categories). Each of these classifications has associated procurement rules and processes that must be followed.
Another contributing factor involves changes in the GSA contracting workforce. The recent reductions in the GSA acquisition workforce due to retirements, re-organizations, and funding restrictions have created a knowledge expertise vacuum and increased performance pressures on the remaining acquisition workforce. In addition recent GSA management reorganizations have caused turnover in contracting officer’s representative (COR) assignments. As a result, many of the CORs have less experience providing the required oversight and guidance to vendors. This has the potential for increased misunderstanding and complaints at critical acquisition junctures. Although procurement managers are executing their responsibilities according to federal procurement laws and GSA guidelines, they lack the resources to support robust training efforts for inexperienced vendors and to provide trend information or best practice information to the vendor community.
A major result of these challenges is an increase in the number of vendor inquiries and complaints which have doubled within the past year. This is particularly problematic because complaints and protests from vendors are currently received and managed through various means. The lack of centralized processing leads to delays and miscommunication which tends to increase the frustration of vendors and results in perceptions that their complaints and inquiries are not being effectively managed. In Appendix A, Table A-1: Strengths, Weaknesses and Opportunities, strengths and weaknesses of current GSA procurement processes are outlined revealing specific opportunities for improvement of current processes through active OPO engagement. Within the table, areas of major concern to industry, the acquisitions community within GSA, and Congress are covered, allowing for a high level overview of the framework within which the OPO will need cooperation and resources from its strategic partners. Table A-1 classifies GSA procurement activities into service delivery process categories and identifies the current strengths and weaknesses within each of these categories. Opportunities to improve these processes through OPO engagement are described in the opportunities column.
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5.0 Future State
In recent years, GSA has taken numerous steps to improve acquisition policies and processes to encourage industry to do business with GSA. The creation of the OPO is another step in strengthening GSA’s relationships with industry. The OPO will develop and facilitate engagement strategies around industry outreach, workforce in-reach, conflict resolution, and process improvements to strengthen GSA’s relationship with industry vendors.
This section describes how the OPO will be integrated into the existing (current state) GSA acquisition infrastructure to improve service delivery. It defines the organizational structure and clarifies how the OPO mission, vision, objectives and strategies will support future acquisition activities. It also identifies stakeholders who will have an interest in future OPO operations. Finally, this section describes the scope, assumptions and constraints associated with OPO activities.
5.1 FUTURE STATE MISSION, VISION, OBJECTIVES, STRATEGY, AND VALUES
Table 5-1 summarizes the Ombudsman’s mission, vision, objectives, strategy, and values.
Table 5-1. Ombudsman Mission, Vision, Objectives, Strategy, and Values
Mission Provide an informal forum for vendors and industry associations who do business with GSA to voice their concerns of unfair practices or disparate treatment in GSA’s acquisition programs and processes.
Vision To be a conduit for fostering frank and open dialogue between GSA and industry that encourages competition and innovation. ● Ensure vendors have ready access to procurement opportunities. ● Ensure vendors can interact and do business with the government with minimal burden and
delay. ● Ensure small businesses have the tools and support they need to successfully work with the
government. ● Ensure vendors understand the government’s procurement processes and know how to seek
business through those processes.
Objectives ● Facilitate a stronger dialogue between government and industry across the GSA enterprise. ● Engage internal and external stakeholders outreach activities. ● Provide confidential and informal assistance to GSA’s vendors and industry associations. ● Advocate for fair processes, but not for any individual or organization, including GSA. ● Act as a facilitator for resolving industry concerns by helping vendors address their concerns in
the most constructive manner and at the most appropriate level within the agency. ● Identify and develop training for the workforce on industry engagement ● Promote responsible administration of acquisition laws, rules and guidelines. ● Promote a public service-culture that contributes towards the improvement of the quality of the
Federal acquisition process; ● recommending equitable redress for justified complaints, ● Contributing towards the improvement of laws and administrative processes/ procedures that are
the source of hardship.
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Strategy ● Outreach and In-reach: Engage with industry to identify issues and trends in the marketplace, and raise awareness of barriers that hinder inclusion, diversity and innovation.
● Conflict Resolution: De-escalate disputes and help resolve issues whenever possible. ● Training: Provide industry engagement training to all acquisition stakeholders. ● Fact Finding: Review and facilitate resolution of procurement issues in a timely fashion.
Standards ● Customer service. OPO will provide customer service to vendors, vendor groups, the GSA acquisition workforce and other stakeholders.
● Independence. The OPO, in function and appearance, shall be free from outside control or influence. This standard enables the OPO to function as an impartial and critical entity that reports findings and makes recommendations based solely on a review of facts and in the light of reason and fairness.
● Impartiality. Receive and review all complaints/inquiries in an objective and fair manner, free from bias, and treat all parties without favor or prejudice, instilling confidence in the public and agencies that all inquiries will receive a fair review, further encouraging all parties to accept the OPO’s findings and recommendations.
● Confidentiality. Ability to keep confidential or release any information related to a complaint or fact-finding, balancing the need to protect sensitive information so that a complainant can come forward, and witnesses can speak openly with regard to disclosing information as part of fact-finding or public report.
● Credibility/integrity. Execute responsibilities in a manner that engenders respect, confidence, and openness to all potential complainants, enabling the OPO to have value and be accepted by all parties to a complaint.
● Neutral. Approach all issues objectively while acting as neither a lobbyist for vendors nor an apologist for federal organizations.
● Knowledgeable. Develop and maintain a high level of understanding and expertise of procurement policies, procedures, trends, and best practices.
● Responsive. React appropriately and promptly to supplier and federal procurement issues. ● Helpful. Share best practices and demystifying the federal procurement process. ● Part of the solution. Identify systemic concerns and make recommendations to strengthen
federal procurement activities.
Goals The OPO will be uniquely situated to strengthen GSA’s corporate commitment to meeting its performance goals, particularly the following: ● Increase support for vendors new to government contracting by helping them understand where
to locate contracting opportunities, processes, policies and available resources offered by the government.
● Increase support for existing vendors who encounter barriers to opportunities and processes. ● Reduce burden on vendors by exploring policy changes, process modernization, and
accelerating time for common transactions. ● Foster two-way communications with government and industry by providing training that centers
on the importance and benefits of meaningful and productive engagement throughout the acquisition process
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5.2 PROPOSED ORGANIZATIONAL STRUCTURE
The Ombudsman will report to GSA’s Senior Procurement Executive. The OPO will be staffed appropriately to manage outreach, conflict resolution, training, and fact-finding activities. The OPO will utilize the assistance of designated Industry Liaisons, Coordinators and Supplier Relationship Management programs across GSA to support its mission, vision and objectives. Figure 5-1 shows the proposed organization for the OPO, while Table 5-2 summarizes the roles of the OPO positions.
Figure 5-1. Office of the Procurement Ombudsman Organization
Immediate requirements to stand up the Office of the Procurement Ombudsman
Future OPO requirements (maturity)
FAS & PBS Liaisons and Managers will support the Ombudsman
Procurement Ombudsman
Outreach & Communications Analyst
Contractor Support (Data analysis)
Training and Procurement Analyst
Industry Coordinator
Industry Liaisons
Supplier Relationship
Manager
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Table 5-2. OPO Positions and Roles
Position Role
Ombudsman • Provides program management, leadership, vision, goals & objectives. • Provides financial oversight and defines the business model. • Oversees activity implementation. • Processs complaints. • Employs in-reach, outreach, and conflict resolution strategies. • Oversees development of acquisition centralization, standardization, and automation
improvement initiatives.
Training & Procurement Analyst
• Performs OPO outreach, training, & conflict resolution activities. • Plans and implements engagement training events. • Identifies potential partnerships with other GSA Offices as well as external industry
associations/organizations. • Provides federal procurement policy support and best practices research to identify
relevant content for training events.
Outreach & Communications Analyst
• Performs OPO outreach, training, & conflict resolution activities. • Publicizes OPO industry outreach events and training opportunities through defined
communication channels. • Plans industry outreach events on behalf of the PO; Partners with other agencies and
organizations to host events. • Records and analyzes industry feedback to determine the most effective channels for
outreach and communication. • Determines which types of events are most useful and beneficial to industry partners and
plans outreach initiatives accordingly.
Contractor Support
• Assists in standing up the program, which includes preparing and performing required administrative and policy research and composing documentation needed to support the program.
• Assists maintaining the OPO Issue Management System. (Includes data management and the evaluation of business system and user needs as they relate to OPO program functions and business strategies.)
• Makes recommendations on the collection and categorizing of vendor inquiries and complaints.
• Facilitates database quality improvement initiatives. • Provides recommendations to the PO on what information should be collected to further
enhance business analytics for decision making purposes. This position works with other staff in the OPO to ensure that the system is capturing and consolidating relevant information for useful report generation to support Office mission and focus OPO program initiatives.
Industry Coordinator
• Channels vendor issues & feedback from industry & ILs to OPO. • Coordinates Industry Liaison (IL) activities with OPO. • Identifies industry groups and vendors for outreach efforts. • Identifies & reports process and policy barriers to OPO. • Assists OPO with development of engagement strategies, program policies, training
development and communication initiatives. • Additional information is provided in Appendix C.
Industry Liaison • ILs will channel vendor issues and recommendations to ICs and OPO. • Provide ICs with feedback from the COs and regional directors on the effectiveness of
efforts to encourage industry engagement. • Work closely with the ICs to identify and suggest training activities and programs that foster
industry engagement.
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Position Role
• Obtain feedback from vendors during procurement debriefing sessions on solicitation and source selection processes.
• Meet regularly with the ICs and the GSA Procurement Ombudsman to share best practices and lessons learned.
• Additional information is provided in Appendix D.
5.3 ASSUMPTIONS
Table 5-3 lists assumptions upon which the OPO will be established and operate. These assumptions highlight the requirement for existing GSA procurement organizations to support OPO activities. These assumptions also highlight the need for annual resourcing as well as continuous access to procurement data systems managed by other internal GSA stakeholders.
Table 5-3. Assumptions
Assumptions
● OPO will have access to acquisition data and systems in order to review the status of vendor submissions (Appendix B).
● OPO will have access to sufficient resources to provide strategic capabilities such as in-reach, outreach, training, fact-finding, and conflict resolution activities.
● FAS and PBS will provide appropriate resources (ICs and ILs) to support the mission and objectives of the OPO, and include requirements in ICs and ILs performance plans.
● OPO will have financial resources to support outreach activities, such as attendance at meetings, conferences and industry day events etc.
● Service and Staff Offices will provide required information to the OPO so it can process vendor complaints.
● Vendors will provide requested information to the OPO so it can fully process problems.
● Service and Staff Offices will assist the OPO in developing complaint resolution metrics to measure progress acquisition improvement initiatives.
5.4 CONSTRAINTS
Table 5-4 lists constraints, both existing and potential, that could restrict or inhibit OPO performance. Most of these constraints are related to resourcing and dependencies on other stakeholders to support OPO activities.
Table 5-4. Constraints
Constraints
● Funding for required OPO activities, training and outreach.
● Funding for contract staff.
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Constraints
● Senior leadership availability and willingness to provide program advocacy.
● Access to internal agency information and data.
● Availability of data to determine best industry focus areas.
● Ability to maintain meaningful contact with all external agencies engaged in acquisition activities.
● Ability to maintain meaningful contact with all vendors and industry groups.
● Amount of time that ILs will be authorized to support OPO requirements.
● FAS and PBS time and resource investment.
● Staff and Service Office willingness to standardize, centralize and automate processes.
● Staff and Service Office willingness to share information in order for the OPO to develop corporate solutions.
● FAS and PBS willingness to include OPO requirements in IL and IC performance plans.
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6.0 Future Service Delivery Model
By bridging the gaps through informal and impartial processes, the Ombudsman will reduce the number of complaints and formal protests, and improve customer service through numerous actions. One of the key actions will be addressing vendor inquiries early with more consistency. This step, along with streamlining the contract management process, will reduce the potential for frustrated vendors to escalate grievances. Another action will involve providing centralized education and outreach to vendors and GSA acquisition practitioners. Increasing their knowledge of the process is expected to reduce differences and improve performance. It is also anticipated that these actions will increase the participation of small business vendors because they will be more knowledgeable of GSA’s procurement processes.
By answering vendor complaints and de-escalating contract disputes early in the process, the Ombudsman will reduce GSA complaint workload which will increase operational efficiencies. Vendor Customer Service satisfaction will also improve.
Decisions to centralize, standardize or automate activities are key considerations for future state acquisition service delivery. As an impartial and objective arbiter who will manage individual vendor inquiries from various GSA organizations, the Ombudsman will be in a unique position to detect redundancy and sub-optimization and recommend standardized, centralized, and/or automated solutions.
The Ombudsman will also stay abreast of new acquisition policies, seek to identify inadequate and inconsistent policies and recommend revisions to reduce costs and improve acquisition outcomes. Inadequate and inconsistent organizational processes will also be identified. Ombudsman process improvement suggestions that take into account all GSA organizational acquisition requirements and vendor needs will be inherently more beneficial than those coming from GSA sources that do not have access to vendor concerns and an enterprise view of GSA.
In addition to the policy and process improvements, GSA will be able to provide a single voice to industry. The Ombudsman will collect, prioritize and resolve industry issues and communicate the GSA position to industry in a timely and consistent manner. The Ombudsman will also review industry feedback and communicate industry improvement recommendations to GSA staff on a regular basis.
In summary, through the work of the OPO, GSA will be better positioned to improve vendor performance and drive value to customers by providing vendors with increased access to accurate and standardized information, and the option to pursue early and informal dispute resolution.
6.1 FUTURE SERVICE DELIVERY STRATEGIES
The GSA Procurement Ombudsman will employ a multi-dimensional strategy to improve acquisition customer service delivery through robust communication strategies (in-reach and outreach), training, and complaint and issue resolution and process improvement. The following sub-sections describe the details associated with these activities.
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6.1.1 Communication
GSA will leverage multiple communication channels including social media, website management, and quarterly newsletters as well as routine and urgent announcements to communicate with industry associations as well as individual vendors, when appropriate.
6.1.1.1 IN-REACH: INTERNAL COMMUNICATION AND COLLABORATION Understanding industry issues will inform the GSA Procurement Ombudsman of opportunities to improve internal GSA processes, policies, and business strategies across GSA’s procurement activities. The GSA Procurement Ombudsman will prioritize and consolidate industry recommendations and inform the GSA acquisition community about improvement opportunities. The GSA Procurement Ombudsman will leverage relationships with GSA procurement activities to implement industry process and policy improvement recommendations. The OPO will bridge communication gaps throughout GSA to promote standardization and efficiency (see Figure 6-1).
Figure 6-1. OPO Communications Model
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The OPO will work closely with GSA senior leadership and GSA offices to ensure routine receipt of industry and vendor recommendations, issues, and complaints in consistent and standard formats.
Key in-reach activities will include:
● Engaging in two-way communication between offices to share information about the role of the OPO and how it may provide assistance, as well as to learn about new initiatives and developments.
● Working with GSA procurement and acquisition leadership to engage industry and improve outreach.
● Working closely with GSA’s Office of Public Engagement and Outreach to coordinate industry-related events and activities involving senior leadership.
● Working with the agency Acquisition Career Manager and the FAI to develop industry relationship training for the acquisition workforce.
● Facilitating increased awareness of current industry products and services. ● Identifying resources and industry training for greater use of small businesses and
subcontracting opportunities. ● Providing periodic reports regarding inquiries and trends identified to the SPE and senior
leadership; based on results of inquiries and fact-findings, providing feedback to senior leadership on ways to improve internal policies and procedures.
● Deferring to General Counsel as needed for advice on vendor conflict resolution.
6.1.1.2 OUTREACH: EXTERNAL COMMUNICATION AND ENGAGEMENT The GSA Procurement Ombudsman will employ outreach strategies to raise awareness and exchange information with industry representatives about existing and potential acquisition issues. The GSA Procurement Ombudsman will meet with industry groups and representatives on a regular basis to review and consider industry issues that require corporate GSA resolution. To foster fair and open dialogue between GSA and industry, the GSA Procurement Ombudsman will serve as a liaison and primary administrator for vetting industry initiatives that are identified during OPO outreach activities. The OPO will serve as the hub of an interconnected web of organizations and stakeholders within GSA, across government, and throughout industry (Figure 6-2).
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Industry
Government Acquisition Partners
All Government agencies that manage acquisition activities
Figure 6-2. OPO Outreach Communication Model
The OPO will cultivate relationships with these stakeholders and promote effective communications by:
● Providing greater clarity of agency requirements to vendors. ● Meeting with industry representatives to discern market trends and advances in
technology to enhance GSA’s ability to make smarter buying decisions, and address concerns, issues, and ideas for improving GSA’s contracting programs and processes.
● Facilitating and promoting learning opportunities and events. ● Fostering relationships with major industry organizations, associations, and councils to
promote OPO initiatives and capture industry trends and concerns. ● Promoting and advancing benefits of healthy industry-government relationships, where
government can benefit from innovation and advances in technology and industry can benefit from greater familiarity with government decision makers and customers.
● Engaging industry and agency leaders to conduct joint training activities for the acquisition workforce.
● Overseeing website implementation that reflects the OPO mission and objectives. ● Establishing a network of individuals to report industry concerns and opportunities. The
network group will include representatives from GSA Staff and Service Offices.
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6.1.1.3 OUTREACH TO VENDORS VIA INDUSTRY COORDINATORS AND INDUSTRY LIAISONS Both FAS and PBS will appoint ILs to resolve vendor issues at the operational (office) level. Both organizations will also appoint ICs to coordinate the activities of the ILs and communicate vendor issues to the OPO (Appendix C and D). The ICs will work closely with the OPO to identify industry groups and vendors for outreach within their respective services. ILs will provide routine updates to ICs (Figure 6-3). Trend information and specific issues will be communicated from ILs to ICs to the OPO, which will resolve issues in order of priority and communicate solutions back to the ICs for further distribution to the ILs and the vendor community.
The GSA Procurement Ombudsman may receive queries (feedback, questions, complaints and suggestions) from vendors directly or via ILs and ICs. As Figure 6-3 illustrates, the Ombudsman will review the queries; decide on appropriate steps; and provide feedback to ICs, ILs vendor communities, vendors, and the GSA acquisition workforce. In cases where additional research or interaction with GSA agencies is required, the GSA Procurement Ombudsman will engage directly with the appropriate organization.
Figure 6-3. Outreach to Vendors via Industry Coordinators and Industry Liaisons
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6.1.2 Training
OPO will collaborate with the Federal Acquisition Institute and other educational organizations to develop training sessions that improve knowledge of the federal acquisition process. This training will be provided to government and industry on a routine basis. Through outreach efforts, OPO will also identify trends where vendors are having difficulties and direct them to resources available at GSA to reduce confusion and help vendors navigate complex processes. In addition, OPO will provide training to the ICs and ILs on appropriate management of vendor issues. OPO training will help bridge the gap between vendors and the acquisition workforce to improve compliance, increase efficiency and reduce the number of complaints that arise out of misunderstandings about policies and processes. Training formats will include video, webinar and live events.
6.1.3 Policy, Process and Complaint Resolution
The OPO will receive complaints, issues, and recommendations from vendors, industry groups, and other federal agencies. All complaints and inquiries will be tracked in a case management system managed by the OPO. It will track all vendor complaints, serve as a repository for industry issues, and will track trends that shed light on the challenges vendors face in doing business with GSA.
The OPO will notify appropriate GSA managers and representative stakeholders about industry issues. OPO will oversee team formation, monitor team activities, help teams develop solutions and coordinate with appropriate stakeholders. OPO will monitor implementation of improvement recommendations and provide status updates to stakeholders, when appropriate (Figure 7-4).
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Figure 6-4. Policy and Process Resolution via the GSA Procurement Ombudsman
GSA does not have a formal process for Ombudsman management of individual vendor complaints. The OPO will develop a formal OPO complaint management process that will provide vendors with an Ombudsman point of entry for complaint resolution. The following conceptual guidelines apply:
• The OPO will conduct an initial evaluation to determine if a vendor complaint warrants fact-finding.
• If the OPO decides not to conduct a fact-finding, it will inform the complainant vendor of the decision and the rationale.
• If the OPO determines a fact-finding is warranted, the fact-finding will be conducted according the standards of independence, impartiality and confidentiality.
• The OPO will conduct all fact-findings in a timely manner and keep both complainants and subjects apprised of the status of the fact-finding.
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• The OPO will use the information gained through management of inquiries to inform a process of continuous improvement.
• Upon resolution of complaints, the Ombudsman will filter results to determine if: • Any lessons learned need to be communicated to ICs, ILs, Industry Groups and the
GSA acquisition workforce. • Any process or policy changes are required.
The GSA Procurement Ombudsman will interact with vendors and the GSA acquisition workforce in an independent, neutral, and confidential manner. Although not assigned decision-making authority or authority to overturn GSA decisions, the Ombudsman will seek to de-escalate disputes and resolve vendor issues through informal processes. The Ombudsman will also work with individual vendors to untangle complicated situations and identify solutions, which could include making specific change recommendations to GSA offices to promote fairness in specific cases.
If policy or process changes are necessary, the Ombudsman will solicit representative stakeholders to develop solution options and coordinate solutions for implementation across the GSA staff. The OPO will track the source, content, key information and disposition of all vendor inquiries they receive. The OPO will track vendor correspondence and maintain a database of issues for recall and trend analysis.
6.1.4 Acquisition Process Improvement
Acquisition programs are continually evaluated for efficiency opportunities. Accordingly, future state Ombudsman service delivery concepts are aligned with GSA priorities: to provide cost savings, optimize resources, and improve customer service.
Three key components will be considered by the OPO to evaluate opportunities for process improvement: standardization, centralization and automation.
Many existing acquisition processes are dependent upon email and point-to-point transactions which are inefficient and create mutual frustration between vendors and the GSA acquisition workforce. The GSA Procurement Ombudsman will work with GSA program managers to standardize, centralize and automate procurement processes across the GSA enterprise, where appropriate. This will ensure fulfillment of required process steps and provide progress visibility to vendors and GSA process owners. Many processes will be centralized to facilitate automation, reduce duplication, streamline operations, and improve customer service. Other processes will remain distributed, where centralization is impractical, but will be standardized to reduce confusion and duplication.
6.2 FUTURE OPERATIONAL APPROACH
Table 7-1 provides a synopsis of the OPO’s future operational approach by function. It lists all the future planned OPO functions and the associated concepts/activities that will be key to
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fulfillment of OPO mission, goals and objectives. The list incorporates all the activities required to provide future service delivery, described in sections 7.1 (above), in tabular format.
Table 6-1. Future Operational Approach
Function Key Concept
In-reach ● Provide centralized support and staffing of industry issues, concerns, and initiatives. ● Manage feedback from GSA staff to industry. ● Promote standardization, centralization, and automation initiatives to improve
efficiency and service delivery.
Outreach ● Employ a coordinated enterprise communication strategy with industry. ● Provide a quarterly newsletter to industry. ● Meet with industry groups on a routine basis to discuss issues and report progress. ● Work with FAS and PBS to identify industry engagement opportunities. ● Engage individual vendors to resolve specific issues. ● Work with ILs and ICs to promote the program and serve as the “eyes and ears” of
GSA.
Complaint Management ● Respond to all vendor complaints. ● Process credible complaints. ● De-escalate contract disputes early.
Complaint Tracking ● Track vendor correspondence and maintain a database of issues for recall and trend analyses.
● Track the source, content, key information, and disposition of all vendor complaints.
Vendor Engagement ● Present or attend vendor engagements to build strong vendor relations and promote its activities.
Vendor Training ● Work with vendor communities to identify training opportunities. ● Engage with vendors and ensure they are part of the training team.
Vendor Issue Management
● Serve as a neutral party for vendor concerns and issues.
Data Management ● Maintain a database that logs the concerns and resolutions of complaints. ● Report results and performance data to FAS senior leadership.
Vendor Trends ● Look for industry trends using information from OFPP and GSA that identify policy or training opportunities.
Vendor Directory and Updates
● Maintain a centralized vendor directory.
6.3 FUTURE BENEFITS
Table 7-2 provides a tabular list of all the anticipated enterprise-wide benefits of OPO program implementation for all procurement stakeholders.
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Table 6-2. Future Benefits
Future Service Plan Benefit
Standardized Processes ● Consistent enterprise-wide acquisition procedures. ● Standardized, centralized processes for GSA acquisition workforce and industry. ● Vendors will recognize and understand processes. ● GSA leaders will recognize and understand processes. ● Increased efficiency. ● Reduced discontinuity and confusion. ● Defined touchpoints for vendors.
Consistent Policies ● Consistent enterprise-wide guidance. ● Standardized and, centralized policies will eliminate confusion for both GSA
employees and vendors. ● Reduced rework to resolve issues that arise out of inconsistent policies. ● Reduced confusion. ● Improved service. ● Reduced vendor complaints. ● Improved GSA posture with industry. ● Improved morale.
Centralized Management of Industry Issues
● Singular management of industry engagement activities will eliminate confusion, reduce workload, and reduce inconsistent messages.
● Enterprise engagement with industry will be managed from one office. ● Centralized data and reporting. ● Labor economies.
Increased Automation ● Improved acquisition service delivery to industry. ● Defined touchpoints. ● Standardized and centralized processing. ● Increased reliability. ● Improved reporting. ● Reduced workload.
Functionally Integrated Processes
● Connected touch points. ● Reduced duplication.
Outreach ● Improved communication between vendors and GSA. ● Improved recognition of industry issues. ● Reduced number of complaints. ● Improved recognition of industry challenges with GSA policies and processes. ● Improved mutual understanding of issues that affect both GSA and industry. ● Increased opportunity to correct misunderstanding of GSA decisions, policies, and
processes. ● Reduced pressure from industry to improve and streamline processes.
Improved Communication ● Codified and planned communication events with industry vendors will improve industry reception and intake of GSA information; create a feedback loop for industry to communicate issues to GSA at an enterprise level; enable GSA to widely distribute industry feedback; and strengthen vendor understanding of GSA processes.
● Increased and improved communication between vendors and GSA acquisition community.
Complaint Management ● Centralized enterprise level informal and early management of industry and individual vendor complaints/inquiries will result in reduced total number complaints, reduced GSA workload, substantial GSA cost savings, and Improved customer service.
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Future Service Plan Benefit
Vendor Training ● Increased vendor knowledge. ● Increased number of vendors following GSA and FAR processes. ● Reduced complaints. ● Reduced GSA rework to accommodate errant vendors.
Data Management ● Expanded knowledge of vendor data, including total number of vendors, total number of issues/complaints received, resolved, outstanding, types of inquiries and trends.
Reporting ● Standardized, centralized, and automated reporting of vendor complaint data will result in more consistent, accurate, and reliable enterprise data.
Enhanced Leadership Awareness
● Reduced confusion. ● Improved corporate posture with industry.
6.4 RELATIONSHIPS AND DEPENDENCIES
Table 6-3 provides a tabular list of the OPO relationships that will need to be cultivated and dependencies that will need to be supported by internal and external stakeholders in order for the OPO to ensure successful program deployment. This list highlights OPO dependency upon internal and external procurement stakeholders to support OPO initiatives.
Table 6-3. Relationships and Dependencies
Organization Dependencies
GSA ● Support for OPO development and implementation.
FAS and PBS ● Process integration. ● Support for integrated policies that include OPO. ● Support for standardization. ● Support for centralization. ● Support for OPO dispute resolution. ● Restructuring to include OPO integration/interaction. ● Access to SSO, FAS and PBS data.
Vendors ● Reception to outreach initiatives.
Industry Liaisons ● Reception to working with OPO.
Industry Coordinators ● Reception to working with OPO.
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7.0 RISKS AND MITIGATION Table 7-1 provides a tabular list of all OPO program risks and mitigation strategies.
Table 7-1. Risks and Mitigation
Risk Mitigation
GS Funding ● Prioritize requirements to ensure most important things get done first. ● Seek alternatives through employee detailing or contract workers. ● Communicate impact of funding deficiencies to GSA stakeholders and leaders.
Contract Funding ● Prioritize requirements to ensure the most important things get done first. ● Communicate impact of funding deficiencies to GSA stakeholders and leaders.
Duplication of Effort (FAS or PBS)
● Continuous program management and periodic communication with stakeholders to define clear lanes of responsibility.
FAS Process Decisions Misaligned with Strategic Standardization and Centralization Goals
● Continuous program management.
PBS Process Decisions Misaligned with Strategic Standardization and Centralization Goals
● Continuous program management.
TTS Process Decisions Misaligned with Strategic Standardization and Centralization Goals
● Continuous program management.
Adequate Resources to Successfully Stand Up OPO
● Detail or transition qualified staff to OPO. ● Supplement with contractor support staff.
Ensuring Active PO Organization Engagement with Internal and External Stakeholders
● Designate SPE as champion. ● Socialize OPO. ● Embed OPO in all industry in-reach and outreach efforts. ● Act as the primary point of contact in resolving industry and vendor issues for all
stakeholders at the GSA enterprise level.
Premature Roll-Out of OPO and Processes
● Develop process for FAS first, then expand throughout GSA.
Process Seen as Roadblock by Stakeholders
● Establish simple processes and staff organization to handle up-front work and allow quick turnaround.
Process Seen as Duplicative by Stakeholders
● Engage stakeholders to coordinate, collaborate, and eliminate duplication.
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8.0 HOW TO CONTACT THE OFFICE OF THE PROCUREMENT OMBUDSMAN
The Office of the Procurement Ombudsman may be contacted via email at [email protected] or [email protected].
Ombudsman Website: www.gsa.gov/ombudsman
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List of Appendices
Appendix A – Strengths, Weaknesses and Opportunities
Appendix B – Required systems Access
Appendix C – Industry Coordinator Description
Appendix D – Industry Liaison Description
Appendix E – Industry Associations
Appendix F – Abbreviations
Appendix G – Development Team
Appendix H -- Approvals
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Appendix A: Strengths, Weaknesses & Opportunities
This section identifies the strengths and weaknesses of current GSA procurement processes and reveals specific opportunities for improvement of current processes through active OPO engagement. Table A-1 classifies GSA procurement activities into service delivery process categories and identifies the current strengths and weaknesses within each of these categories. Opportunities to improve these processes through OPO engagement are described in the opportunities column.
Table A-1. Strengths, Weaknesses & Opportunities
Service Delivery Strengths Weaknesses Opportunities
Vendor Acquisition Processing
● FAS, PBS, OAS and 18F all have formal acquisition processes that vendors can follow.
● Processes work when followed.
● Some vendors do not understand or follow GSA acquisition processes.
● Processes vary among the services.
● Processes vary among contracting officers.
● Some process differences result from managerial preferences.
● Justifiable process differences are not adequately explained to vendors.
● Some vendors are confused by the variation in processes.
● Vendor submissions do not get executed because of process compliance problems.
● OPO can assist in standardizing acquisition processes, where appropriate.
● OPO can explain processes to vendors.
● OPO can explain rationale for process differences.
● OPO can provide formal and informal process training to vendors and vendor communities.
GSA Acquisition Processing
● FAS, PBS, OAS and 18F have formal acquisition processes that all GSA acquisition workforce personnel can follow.
● Processes vary among the services and across regions.
● Some GSA acquisition workforce practitioners do not follow established processes.
● Some process differences may result from managerial preferences.
● Justifiable process differences are not always adequately explained to vendors.
● Acquisition workforce failure to comply with GSA processes can cause a significant delay in vendor submissions.
● OPO can detect areas where GSA’s processes are not being followed by GSA acquisition practitioners.
● OPO can explain processes to errant GSA acquisition practitioners.
● OPO can provide formal training to GSA acquisition community.
● OPO can provide informal training through meetings with individuals and groups of acquisition practitioners.
● OPO can facilitate consistency in processes (where applicable) across the GSA enterprise
GSA Contract Modification
FAS, PBS, OAS and 18F have somewhat defined contract modification procedures.
● GSA contract modification procedures vary across organizations.
● GSA contract modification procedures vary among GSA acquisition workforce practitioners.
● OPO can assist in standardizing contract modification processes across GSA.
● OPO can explain process differences to vendors in instances where there are
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Service Delivery Strengths Weaknesses Opportunities
● GSA contracting practitioners require different documents for the same type of contract modification.
rationales for the differences.
Timing Standards
FAS, PBS, OAS and 18F have defined contract timing standards for contract submission, response, and processing.
● GSA acquisition time limits for submission, response, and processing are not standardized; they vary across GSA.
● Some acquisition practitioners do not follow timing standards.
● Some acquisition practitioners may set arbitrary time limits for contract submission, response, and processing, including receipt of documents. This can result in inadequate vendor preparation/submissions.
● OPO can provide vendors and vendor communities with prescribed timing guidelines.
● OPO can explain exceptional case and areas where timing may vary.
● OPO can intercede in cases where timing is inappropriate and not aligned with GSA standards.
GSA Contract Document Collection and Processing
FAS, PBS, OAS and 18F define required documents and collect and review vendor documents when evaluating proposal information.
● GSA document requirements are inconsistent.
● GSA contract document requirements vary across organizations.
● GSA acquisition practitioners require different documents for the same type of contracts.
● OPO can explain differences in document requirements to vendors and vendor communities.
● OPO can intercede when GSA acquisition practitioners request documents that are not aligned with defined standards.
Vendor Communication/Engagement (ALL)
Most GSA contracting officers and acquisition practitioners provide some level of customer support to vendors.
● Some vendors cannot access GSA customer service capabilities because they are distributed among FAS, PBS, and SSO offices.
● Some contracting officers and acquisition practitioners do not respond to vendor (customer) requests for assistance or information.
● Vendors have no recourse when contracting officers or acquisition practitioners are non-responsive.
● Some vendors identify GSA responsiveness as a critical process fault.
● GSA has no recourse because vendor requests are not centrally managed or tracked.
● There is no centralized system or process for vendors to request assistance.
● GSA cannot determine the number of customer requests generated or answered.
● Vendor requests for assistance
● OPO can standardize customer service response processes across GSA.
● OPO can educate vendors about the availability of customer service options.
● OPO can follow up with agency personnel when quality customer service is not being provided.
● OPO can be an additional avenue for vendors to receive better customer service.
● OPO can implement and manage a centralized and automated customer request system to track requests.
● OPO can collect and provide customer request and response metrics.
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Service Delivery Strengths Weaknesses Opportunities
or information is not tracked in a centralized automated customer service delivery system.
Customer Inquiries
Most GSA contracting officers and acquisition practitioners respond to customer inquiries.
● There is no centralized response plan or process for GSA to respond to vendor inquiries.
● Inquiring vendors may receive inconsistent messages, information, and instructions from varying GSA sources.
● Some vendors exploit inconsistencies by seeking preferable answers from various GSA sources.
● OPO can standardize vendor inquiry responses across GSA.
● OPO can work with FAS, PBS, and SSO contracting officers and acquisition practitioners to develop standard responses to customer inquiries.
● OPO can conduct research to provide answers to more challenging customer inquiries.
● OPO can refer customers to GSA experts when required.
Vendor Inquiries/Complaints
Most GSA acquisition offices have processes in place to address vendor complaints.
● In some cases acquisition practitioners do not respond to vendor (customer) complaints.
● Vendors have no recourse when acquisition practitioners are non-responsive.
● Some vendors identify GSA responsiveness as a critical acquisition process fault.
● Vendor inquiries are not centrally managed or tracked.
● GSA has no idea how many vendor inquiries are generated and how many are answered at the enterprise level.
● Vendor complaints are not tracked in a centralized, automated customer complaint service delivery system.
● OPO can implement a standardized, centralized, and automated customer complaint review and response delivery system.
● OPO can educate vendors about the process to make complaints.
● OPO can follow up with agency personnel to resolve unanswered customer complaints.
● OPO can be an additional avenue for vendors to submit complaints.
● OPO can implement and manage a centralized and automated system to track vendor complaints.
● OPO can collect and provide customer complaint and response metrics.
Complaint Resolution Effectiveness
FAS, PBS, OAS and 18F respond to customer complaints.
● GSA’s responses to inquiries are inconsistent.
● Some complaint responses and remedies vary among GSA organizations.
● Some complaint responses and remedies vary among GSA managers and contracting officers.
● OPO can standardize complaint responses for similar situations across GSA.
● OPO can integrate standardized response capabilities to inquiries/complaints to ensure a consistent GSA response, when appropriate.
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Service Delivery Strengths Weaknesses Opportunities
Supplier Relationship Management (SRM)
FAS and PBS have established SRM programs.
● FAS and PBS are managing SRM as internal programs; there is no enterprise-wide SRM program. This leads to inconsistent resolution of vendor inquiries.
● There are no centralized SRM metrics.
● SRM cross-talk opportunities between organizations are not optimized.
● OPO can work with GSA organizations to develop a centralized SRM program to provide an integrated view of the GSA SRM activities.
Performance Metrics
Some GSA acquisition organizations collect performance metrics.
● Some organizations do not collect performance metrics.
● Missing GSA enterprise metrics include: ● Number of vendor inquiries ● Number of vendor complaints
resolved ● Number of vendor complaints
open.
● OPO can work with acquisition organizations to develop standardized metrics for compliant/inquiry processing and reporting.
● OPO can work with OGP and OCSIT to develop an automated, centralized and standardized metric performance system.
Reports and Analyses
Some GSA acquisition organizations conduct analyses and publish reports.
● There are no enterprise-wide comprehensive acquisition reports that provide standard performance metrics (see above) and standard information regarding vendor inquiries and complaints, including the following: ● Number of vendor inquiries ● Number of vendor
complaints ● Number of vendor
complaints resolved ● Number of vendor
complaints open.
OPO can work with acquisition organizations to establish enterprise-wide reports containing standard information regarding vendor inquiries and complaints.
Centralization Some GSA acquisition functions, processes, and reports are centralized.
● Some GSA acquisition functions, processes, and reports are not centralized.
● Centralizing GSA activities, processes and reports would improve efficiency.
● OPO can work with acquisition stakeholders to identify opportunities for centralization of acquisition activities.
Standardization
Some GSA acquisition functions, processes, and reports are standardized across GSA.
● Some GSA acquisition functions, processes, and reports are not standardized.
● Standardizing GSA activities, processes, and reports would improve its acquisition efficiency.
● OPO can work with acquisition stakeholders to identify opportunities for standardization of acquisition activities.
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Service Delivery Strengths Weaknesses Opportunities
Automation of Vendor Relationship Management Processes
GSA acquisition organizations manually track responses to vendor inquiries, requests, and complaints.
● Most GSA acquisition organizations use manual processes to track vendor inquiries, requests, and complaints, resulting in: ● Increased manpower to
manage labor- intensive steps ● Inconsistent, incorrect, and
uncoordinated responses ● Inability to measure and
monitor GSA responses to vendor inquiries, requests, and complaints.
● Automating the vendor inquiry and complaint processes would require fewer personnel, reduce the frequency of disconnects and lost complaints, improve response quality, and decrease transaction time between vendor inquiries and GSA’s responses.
● Additionally, vendors would be able to seek resolution of issues using a singular well- defined process, with extensive visibility of vendor inquiries and GSA responses.
● OPO can work with all acquisition stakeholders to develop and implement an automated Vendor Relationship Management system.
Automation GSA acquisition organizations share some automated tools.
● Not all automated tools are used consistently across GSA.
● Process differences result in inconsistent inputs and outputs.
● There are additional opportunities for automation of GSA’s acquisition processes.
● Developing enterprise acquisition solutions will reduce duplication, improve efficiency, and save resources.
● OPO can help facilitate development of automated acquisition tools by working with GSA stakeholders to develop automation requirements.
Industry Engagement
None ● A recent industry survey revealed the following GSA deficiencies:
● Inadequate communication ● Unresponsiveness ● Lack of understanding of vendor
business processes ● Global acquisition fairness
complaints ● Lack of industry engagement.
● OPO will become the focal point for GSA industry engagement through outreach, promotion, and participation in industry events.
Website Management
FAS and PBS have active websites that provide process guidance to vendors.
● There are no contact points for vendors who are having difficulty following existing processes.
● OPO can develop and maintain a website that provides additional process information to vendors.
● OPO can ensure that all website information is consistent.
Org Communication
Internal organizational communications processes exist in PBS,
● Internal organizational communications regarding vendor acquisition concerns are
● OPO can provide integrated communications regarding vendor acquisition concerns.
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Service Delivery Strengths Weaknesses Opportunities
FAS, and SSO offices. not integrated.
Org Communication
Some organizations are good at communicating with industry.
● Some organizations are not good at communicating with industry.
● There is no consistent communication plan or message to industry.
● OPO can develop an enterprise vendor communications plan.
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APPENDIX B: OPO REQUIRED SYSTEM ACCESS Table B-1 describes a sample list of systems that OPO will be required to access. It is not an exhaustive list. It does not intend to construe that OPO will only be provided access to the listed systems. Rather, this list is a guide to indicate the types of systems OPO will routinely access in order to improve procurement outcomes.
Table B-1. Federal Acquisition Service Future Service Delivery via GSA Procurement Ombudsman
System Description
Acquisition Gateway An innovative workspace where acquisition professionals can act as one government-wide community to find unbiased advice, share expertise, and contribute to continued development.
Interact Online blog in which users engage and discuss views on a variety of trending topics and learn about upcoming events and training opportunities.
GSA Advantage! An online shopping and ordering system with access to thousands of contractors and millions of services and products.
GSA Global Supply A system for ordering GSA products at any time from a vast selection of supplies for government customers anywhere in the world.
GSA Carbon Footprint Tool
A tool for helping agencies manage their greenhouse gas emissions as required by Executive Order 13514 and recent energy laws.
Green Products Compilation
A tool that facilitates the procurement of green products and services.
FedBizOpps A single government point of entry for federal government procurement opportunities of more than $25,000.
eBuy An online request for quote tool for a wide range of GSA commercial services and products.
eOffer/eMod A tool for submitting and modifying proposals electronically.
e-Resolve A system for reporting problems with a GSA Global Supply order or submitting an inquiry about other products and services offered.
Centralized Mailing List Service
A service for ordering publications and GSA Global Supply catalogs.
Schedule Sales Query A source for sales information reported by contractors for specific quarters during the current and past five fiscal years.
Small Business Resources
A process for connecting small businesses to in-person and online training, counseling, procurement opportunities, and more.
GSA eLibrary An online source for schedule contract award information searchable by contractor name, contract number, special item number, schedule number, or keyword.
Federal Procurement Data System
Single source for US Government-wide procurement data.
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APPENDIX C: INDUSTRY COORDINATOR DESCRIPTION Both PBS and FAS will be responsible for identifying Industry Coordinators (ICs) to focus on their respective issues. The ICs will coordinate activities of the Industry Liaisons (ILs) with those of the GSA Procurement Ombudsman, and work closely to identify industry groups and vendors for outreach efforts. Since PBS works primarily with a small number of associations and non-governmental organizations, and FAS deals directly with numerous vendors and associations, the demands on the PBS IC will be substantially fewer than those on the FAS IC.
The responsibilities of the IC include the following:
● Identifying potential barriers that COs face with vendors, and reporting the information to the GSA Procurement Ombudsman.
● Working with the GSA Procurement Ombudsman to identify potential barriers faced by vendors. ● Working with the GSA Procurement Ombudsman to identify trade groups, associations, and
industries for outreach efforts. ● Working closely with the GSA Procurement Ombudsman to develop and rollout the OPO’s
website, ensuring that information relevant to FAS and PBS is displayed. ● Assisting the GSA OPO with identifying potential training for the acquisition workforce,
including collaboration with FAS and PBS acquisition training managers. ● Helping the GSA Procurement Ombudsman develop a toolkit for GSA’s acquisition workforce
that focuses on how to better engage both industry and customers. ● Working closely with the acquisition workforce and the GSA Procurement Ombudsman to
identify, promote, and increase the number of industry day events. ● Coordinate regular meetings with the GSA Procurement Ombudsman and the ILs to learn what
vendor outreach strategies are working within FAS and PBS. ● Working closely with supplier management offices to obtain the number of GSA Interact “hits” to
gauge the effectiveness of outreach activities. ● Working closely with the GSA Procurement Ombudsman to implement components of OMB’s
government-wide Acquisition 360 Initiative. ● Working closely with the GSA Procurement Ombudsman to coordinate GSA’s co-sponsorship of
the Acquisition Excellence 2015 Conference. ● Providing and updating the GSA Procurement Ombudsman with FAS and PBS information and
blogs for the GSA website. ● Developing methods for utilizing feedback from vendors during procurement debriefing sessions
on solicitation and source selection processes. ● Conducting bi-weekly briefing meetings with the ILs to develop field reports and vendor
comments for the GSA Procurement Ombudsman. ● Identify and develop streamlined methods for the ILs and vendors to communicate concerns with
the GSA Procurement Ombudsman. ● Working with various offices to produce fact and information sheets for the OPO’s website. ● Tracking and providing comments from Open-Dialog for use in the GSA Procurement
Ombudsman’s vendor outreach and website activities. ● Working with FAS and PBS to identify vendor and customer surveys that can be used for
developing industry milestones. ● Attending meetings, industry events, and conferences with the GSA Procurement Ombudsman.
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APPENDIX D: INDUSTRY LIAISON DESCRIPTION The Industry Liaisons will be the “eyes and ears” of the GSA Procurement Ombudsman at the operational and regional levels. They will meet bi-weekly with the ICs to provide updates on outreach activities and to share information.
The ILs will be responsible for the following activities:
● Providing the ICs with feedback from the COs and regional directors on the effectiveness of efforts to encourage industry engagement.
● Working closely with the ICs to identify and suggest training activities and programs that foster industry engagement.
● Obtaining feedback from vendors during procurement debriefing sessions on solicitation and source selection processes.
● Meeting regularly with the ICs and the GSA Procurement Ombudsman to share best practices and lessons learned.
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APPENDIX E; INDUSTRY ASSOCIATIONS The Office of the Procurement Ombudsman nurtures relationships with major professional associations and councils to collaborate and communicate with industry and other stakeholders. These relationships are vital channels for communicating and receiving feedback from vendors. The OPO will work with the following major associations to promote industry outreach:
• Key Industry Associations/Councils • American Council for Technology—Industry Advisory Council (ACT-IAC) • Armed Forces Communications and Electronics Association (AFCEA) • American Bar Association (ABA) Section on Public Contract Law • Coalition of Federal Ombudsman (COFO) • Coalition for Government Procurement (CGP) • Information Technology Industry Council (ITIC) • International Ombudsman Association (IOA) • National Contract Management Association (NCMA) • National Defense Industry Association (NDIA) • National Manufacturers Association (NMA) • Procurement Round Table (PRT) • Professional Services Council (PSC).
In addition, the OPO will encourage existing and new vendors to engage with these associations and councils, as well as to contact OPO directly.
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APPENDIX F; ABBREVIATIONS Abbreviation Definition
CAO Chief Acquisition Officer
CO Contracting Officer
COR Contracting Officer’s Representative
FAR Federal Acquisition Regulation
FAS Federal Acquisition Service
GSA General Services Administration
HUB Historically Underutilized Business
IC Industry Coordinator
IL Industry Liaison
IOA Industrial Operations Analysts
IRD Industry Relations Division
IRM Industry Relations Manager
OFPP Office of Federal Procurement Policy
OGC Office of the General Counsel
OMB Office of Management and Budget
OPO Office of the Procurement Ombudsman
OSBU Office of Small Business Utilization
PBS Public Building Service
PM Program Manager
PO Procurement Ombudsman
SBA Small Business Administration
SPE Senior Procurement Executive
TTS Technology Transformation Service
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APPENDIX G: DEVELOPMENT TEAM Name Position
Millisa Gary GSA Procurement Ombudsman
Christiane Monica FAS – Industry Coordinator
Yvette Waugh OGP Program Support Advisor
Suzanne Winnard OGP – Contracting Officer’s Representative
Don Smith LMI Program Manager
Sharon Pringle LMI Program Manager
Maj Jafari eGlobal Tech Program manager
Charlie King LMI Consultant
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APPENDIX H: APPROVAL
___________________________________________________________ Signed Date GSA Senior Procurement Executive
_________________________________________________________ Signed Date GSA Procurement Ombudsman
