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May 8, 2017

Opportunities Exist for FAA To Strengthen Its Award and Oversight of eFAST Procurements

Self-Initiated
Project ID: 
ZA2017046
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In 2009, the Federal Aviation Administration (FAA) developed a small business procurement vehicle known as Electronic FAA Accelerated and Simplified Tasks (eFAST), which offers a broad range of professional and support services. As of December 2016, more than 520 small businesses have been prequalified and hold agreements under eFAST to potentially provide prime contractor services in one or more of eight functional areas. The total maximum value of these agreements is $7.4 billion over a 15-year period. Given the significant Federal dollars involved, we initiated this audit to evaluate FAA’s processes for awarding and overseeing eFAST procurements.

FAA’s processes for awarding eFAST procurements have areas for improvement. Specifically, FAA does not apply its own requirement to verify prospective contractor eligibility when it makes most eFAST awards. As a result, we found that 7 of 40 sample eFAST procurements—totaling over $67 million—had been awarded to firms whose small/disadvantaged eligibility status had expired. Based on this finding, we estimate that $314 million could have been put to better use by awarding those dollars to firms whose eligibility had been verified at the time of the award. Additionally, the majority of FAA’s eFAST procurements involved two high-risk award strategies—selecting time and material (T&M) contract type and awarding noncompetitively. However, the Agency generally did not justify the decision to use T&M type and may have missed opportunities to increase competition among prequalified small/disadvantaged businesses. Finally, FAA does not use performance-based contracting methods for its eFAST procurements, although its policies say such methods should be used for support-service procurements whenever possible.

Furthermore, FAA’s oversight of eFAST procurements is limited by various factors, including contracting officer representatives (COR) without specific procurement expertise or proper certifications, and infrequent communication between contracting officers and CORs. In addition, the Agency lacks documented oversight plans, adequately defined acceptance criteria, and sufficient evidence of any oversight that did occur. We made eight recommendations to strengthen FAA’s eFAST award and oversight processes. The Agency concurred with seven and partially concurred with one—disagreeing with the $314 million we identified as funds put to better use.

Recommendations

Open

Closed

Closed on 08.01.2019
$314,000,000
No. 1 to FAA

Develop and implement a process to require contracting officers to re-verify and document a firm's small/disadvantaged eligibility prior to awarding each individual procurement awarded under an eFAST master ordering agreement. Implementation of this recommendation could put $314 million in funds to better use by awarding those dollars to firms whose small/disadvantaged eligibility status was verified at the time of individual procurement award.

Closed on 12.13.2017
No. 2 to FAA

Develop and implement a process to periodically verify that justifications required by AMS section T3.2.4.A.6(c) are documented for each time and material type procurement awarded under an eFAST master ordering agreement, and that the justification addresses each of the four elements required (including explanations for why any of the individual elements were not addressed).

Closed on 12.13.2017
No. 3 to FAA

Strengthen guidance on utilizing performance-based contracting methods in service contracting, and train contracting and program staff how to use these methods in procurements awarded under an eFAST master ordering agreement.

Closed on 10.25.2017
No. 4 to FAA

Develop and implement a process to periodically verify that eFAST contracting officers are tracking contracting officer representatives' certifications and documenting them in the procurement files.

Closed on 10.25.2017
No. 5 to FAA

Develop and implement a process to promote regular communication between eFAST contracting officers and contracting officer representatives during the period of performance for procurements awarded under an eFAST master ordering agreement.

Closed on 12.13.2017
No. 6 to FAA

Develop and implement a process to promote contracting officer representatives to document and follow oversight plans for procurements awarded under an eFAST master ordering agreement, tailoring each plan to the procurement's unique risks and circumstances.

Closed on 12.13.2017
No. 7 to FAA

Develop and implement a process requiring contracting officer representatives to determine and document how they will validate that statement of work acceptance criteria have been met for each procurement awarded under an eFAST master ordering agreement.

Closed on 12.13.2017
No. 8 to FAA

Develop and implement a process requiring contracting officer representatives to maintain documented evidence of oversight for each procurement awarded under an eFAST master ordering agreement in either the official procurement files on FAA's eFAST Knowledge Services Network workspace, or in a format that is also accessible at any time to the eFAST office