DOE Contracting
Improved Program Management Could Help Achieve Small Business Goal Gao ID: GAO-06-501 April 7, 2006Federal policy requires that small businesses receive the maximum practicable opportunity for providing goods and services to federal agencies through prime contracts--direct contracts between the government and a contractor. The Department of Energy (DOE) buys more than $20 billion in goods and services annually. GAO was asked to (1) discuss DOE's key efforts to increase small business prime contracting opportunities and (2) identify the management challenges DOE faces in improving its small business prime contracting performance. In addition to these objectives GAO is providing information on the management of small business programs by other federal agencies that either share certain characteristics with DOE's largest program offices or that have components that share certain characteristics with these offices.
Key DOE efforts to increase small business prime contracting have included identifying more contracting opportunities for small businesses, expanding small business development and outreach activities, and increasing program management and oversight. The department has had some success in redirecting to small businesses portions of contracts to manage large DOE facilities, as well as in securing additional small business prime contracting opportunities from the department's other contracts. As a result, the total dollars awarded annually as prime contracts to small businesses have increased, and the share of procurement dollars awarded to small business in 2005 was DOE's second highest ever. Despite these gains, however, DOE was unable to meet its small business prime contracting goal in 4 of the past 5 years. DOE faces two key management challenges to improving its small business program. Addressing these challenges will bring DOE's small business program more in line with the practices associated with high-performing organizations and with principles contained in the Government Performance and Results Act. Specifically, DOE has not defined the concrete steps necessary to enable it to achieve its prime contracting goal and does not collect sufficient information to effectively assess its small business program efforts, identify problems, and implement changes that could further increase small business prime contracting. Other federal agencies with missions or agency components with missions similar to DOE periodically comprehensively evaluate their programs to determine effectiveness, identify problems and make changes intended to improve performance. GAO obtained information from the following three agencies: the National Aeronautics and Space Administration, the Department of the Army (U.S. Army Corps of Engineers), and the Department of Health and Human Services (Centers for Disease Control and Prevention).
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-06-501, DOE Contracting: Improved Program Management Could Help Achieve Small Business Goal
This is the accessible text file for GAO report number GAO-06-501
entitled 'DOE Contracting: Improved Program Management Could Help
Achieve Small Business Goal' which was released on April 10, 2006.
This text file was formatted by the U.S. Government Accountability
Office (GAO) to be accessible to users with visual impairments, as part
of a longer term project to improve GAO products' accessibility. Every
attempt has been made to maintain the structural and data integrity of
the original printed product. Accessibility features, such as text
descriptions of tables, consecutively numbered footnotes placed at the
end of the file, and the text of agency comment letters, are provided
but may not exactly duplicate the presentation or format of the printed
version. The portable document format (PDF) file is an exact electronic
replica of the printed version. We welcome your feedback. Please E-mail
your comments regarding the contents or accessibility features of this
document to Webmaster@gao.gov.
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed
in its entirety without further permission from GAO. Because this work
may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this
material separately.
Report to the Committee on Small Business and Entrepreneurship, U.S.
Senate:
United States Government Accountability Office:
GAO:
April 2006:
DOE Contracting:
Improved Program Management Could Help Achieve Small Business Goal:
GAO-06-501:
GAO Highlights:
Highlights of GAO-06-501, a report to Committee on Small Business and
Entrepreneurship, U.S. Senate:
Why GAO Did This Study:
Federal policy requires that small businesses receive the maximum
practicable opportunity for providing goods and services to federal
agencies through prime contracts”direct contracts between the
government and a contractor. The Department of Energy (DOE) buys more
than $20 billion in goods and services annually. GAO was asked to (1)
discuss DOE‘s key efforts to increase small business prime contracting
opportunities and (2) identify the management challenges DOE faces in
improving its small business prime contracting performance. In addition
to these objectives GAO is providing information on the management of
small business programs by other federal agencies that either share
certain characteristics with DOE‘s largest program offices or that have
components that share certain characteristics with these offices.
What GAO Found:
Key DOE efforts to increase small business prime contracting have
included identifying more contracting opportunities for small
businesses, expanding small business development and outreach
activities, and increasing program management and oversight. The
department has had some success in redirecting to small businesses
portions of contracts to manage large DOE facilities, as well as in
securing additional small business prime contracting opportunities from
the department‘s other contracts. As a result, the total dollars
awarded annually as prime contracts to small businesses have increased,
and the share of procurement dollars awarded to small business in 2005
was DOE‘s second highest ever. Despite these gains, however, DOE was
unable to meet its small business prime contracting goal in 4 of the
past 5 years (see table below).
DOE faces two key management challenges to improving its small business
program. Addressing these challenges will bring DOE‘s small business
program more in line with the practices associated with high-performing
organizations and with principles contained in the Government
Performance and Results Act. Specifically, DOE has not defined the
concrete steps necessary to enable it to achieve its prime contracting
goal and does not collect sufficient information to effectively assess
its small business program efforts, identify problems, and implement
changes that could further increase small business prime contracting.
Other federal agencies with missions or agency components with missions
similar to DOE periodically comprehensively evaluate their programs to
determine effectiveness, identify problems and make changes intended to
improve performance. GAO obtained information from the following three
agencies: the National Aeronautics and Space Administration, the
Department of the Army (U.S. Army Corps of Engineers), and the
Department of Health and Human Services (Centers for Disease Control
and Prevention).
DOE‘s Small Business Contracting Goals, Achievements, Fiscal Years 2001
through 2005
[See PDF for table]
Source: GAO analysis of DOE data.
Note: Data are adjusted for inflation and expressed in 2005 constant
dollars.
[End of table]
What GAO Recommends:
GAO recommends that DOE define the concrete steps it will take to
achieve further progress toward its annual goal, collect relevant
performance information to better gauge the effectiveness of its
efforts, and use performance information to support program
improvements as needed.
In commenting on this report, DOE concurred with the findings and
recommendations and described steps it will take to further improve its
small business efforts.
www.gao.gov/cgi-bin/getrpt?GAO-06-501.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
DOE Efforts to Increase Contracts with Small Businesses Have Had
Partial Success:
Two Key Management Challenges Hinder DOE's Efforts to Further Improve
Its Small Business Contracting Performance:
Other Federal Agencies Use Formal Program Evaluation to Guide Changes
in Their Small Business Programs:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Comments from the Department of Energy:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Major Office of Environmental Management Procurements That
Redirect Work Traditionally Performed by Large Businesses with Facility
Management Contracts to Small Business Prime Contracts:
Table 2: DOE's Small Business Prime Contracting Goals and Achievements,
Fiscal Years 2001 through 2005:
Table 3: Practices of High-Performing Organizations Compared with DOE
Small Business Program Practices:
Table 4: Comparison of DOE, Department of Defense, Health and Human
Services, and National Aeronautics and Space Administration Small
Business Prime Contracting Performance, Fiscal Year 2004:
Abbreviations:
DOE: Department of Energy:
FPDS-NG: Federal Procurement Data System--Next Generation:
NASA: National Aeronautics and Space Administration:
NNSA: National Nuclear Security Administration:
SBA: Small Business Administration:
United States Government Accountability Office:
Washington, DC 20548:
April 7, 2006:
The Honorable Olympia J. Snowe:
Chair:
The Honorable John F. Kerry:
Ranking Member:
Committee on Small Business and Entrepreneurship:
United States Senate:
The federal government spends nearly $300 billion annually to obtain
goods and services ranging from military aircraft to office supplies,
from nuclear waste storage to grounds keeping. While most of these
purchases are through contracts with large businesses, the federal
government's policy is to contract with small businesses to the maximum
extent feasible.[Footnote 1] Among other things, directing federal
funds to small businesses can increase competition and contribute to
the economic well-being of the nation.[Footnote 2] The Small Business
Act, as amended by the Small Business Reauthorization Act of 1997
requires that the federal government, as a whole, award at least 23
percent of federal prime contracting dollars to small businesses
annually.[Footnote 3] The Small Business Administration, which oversees
the federal small business program, negotiates an appropriate
individual prime contracting goal with each federal agency,[Footnote 4]
including the Department of Energy (DOE). The specific percentage goal
varies from agency to agency, depending upon agency program missions,
procurement requirements, and past procurement history. Both the
Federal Acquisition Regulation and DOE-specific acquisition regulations
govern the administration of the department's procurements. In
addition, DOE has issued internal guidance in the form of acquisition
letters, secretarial memoranda, and other communications to outline
additional small business requirements. Broadly, these requirements
direct procurement officials to contract with small businesses unless
specific and limited circumstances prevent doing so. For example, an
exemption from small business prime contracting requirements is allowed
if capable small businesses cannot be found to perform the needed work
at a fair price.
DOE is the largest civilian contracting agency in the federal
government, with procurements of approximately $22.8 billion for fiscal
year 2005, or more than 90 percent of its annual budget. DOE relies
primarily on "facility management contractors"--traditionally large
businesses and universities--to manage operations at sites across the
country. These contractors maintain the nation's nuclear weapons
stockpile, clean up radioactive and hazardous wastes, and conduct
complex scientific research, among other activities. According to DOE,
in fiscal year 2005, the department paid 87 percent of its procurement
dollars to 43 facility management contracts. Given the broad scope and
complexity of the work conducted, many of these contracts are for
hundreds of millions of dollars annually, with four contracts exceeding
$1 billion annually. The remaining 13 percent of DOE's procurement
dollars were awarded through contracts with nonfacility management
contractors, many of them small businesses, for things like legal
services and facility design and construction activities.
The administration of DOE's small business program spans several
different organizational units. DOE's Office of Small and Disadvantaged
Business Utilization (referred to in this report as DOE's Small
Business Office) is responsible for establishing small business policy
and implementing the department's small business program, including
engaging in small business outreach and business development activities
and encouraging the department to meet its small business contracting
goal. DOE's Office of Procurement and Assistance Management and the
Office of Acquisition and Supply Management of the National Nuclear
Security Administration (NNSA) set overall procurement policy and are
responsible for ensuring that these policies are followed by
procurement officials and contracting officers throughout the
department. In addition, these offices coordinate with DOE's Small
Business Office in setting small business policy. The NNSA and DOE
program offices such as the Office of Science and the Office of
Environmental Management determine their procurement needs and identify
small business contracting opportunities.[Footnote 5] Small business
contacts in each program office support the small business activities
within their respective organizational units.
In 1999, a change in federal procurement policy affected how DOE set
its annual small business prime contracting goal and measured its
achievement. Prior to the change, federal policy allowed DOE to include
the small business subcontracts of its large facility management
contractors when developing its goal and calculating its small business
prime contracting achievement.[Footnote 6] This prior policy, which
applied only to DOE, reflected a view that the facility management
contractors were acting as surrogates for the department and,
therefore, the subcontracts were equivalent to DOE prime contracts. In
1999, the Office of Federal Procurement Policy changed the policy so
that DOE could not include the subcontracts issued by facility
management contractors when developing small business prime contracting
goals or when calculating actual achievements.[Footnote 7] Given this
decision, DOE's small business prime contracting goal was adjusted
downward from 18 percent in 1999 to 5 percent in 2000. DOE's fiscal
year 2006 goal for small business prime contracting is 5.5 percent of
its total contracting dollars.
In 2004, we testified that DOE had and would continue to have
difficulty meeting its near-term and long-term small business prime
contracting goals but was taking steps to improve results, including
enhancing its small business outreach efforts and assessing facility
management contracts up for renewal to identify work that might be
redirected to small businesses.[Footnote 8] For this report, you asked
us to (1) provide an update on DOE's key efforts to increase small
business prime contracting opportunities and the results of these
efforts to date and (2) identify the management challenges DOE faces in
improving its small business prime contracting performance. In addition
to these two objectives, at your request, we are providing information
on the management of small business programs by other federal agencies
that either share certain characteristics with DOE's largest program
offices or that have components that share certain characteristics with
these offices.
To evaluate DOE's key small business efforts and their results to date,
we reviewed federal regulations, DOE guidance and management directives
concerning small business prime contracting, departmentwide and program-
specific small business plans, and budget documents. We reviewed DOE
contract data from the Federal Procurement Data System, the federal
government's repository of information regarding the nature and value
of contract awards, as well as from a DOE-specific procurement
database. In addition, we reviewed the activities of the DOE Small
Business Office and the small business prime contracting activities at
NNSA and DOE's Offices of Environmental Management and of Science,
which collectively account for the bulk of DOE's prime contracting. In
conducting these reviews, we interviewed DOE small business,
procurement, and program officials.
To identify the management challenges DOE faces in improving its small
business prime contracting performance, we compared the management
practices of DOE's small business program with established management
principles. We interviewed DOE small business and procurement officials
and reviewed program guidance, management directives, and program
performance plans to determine the current practices supporting the DOE
small business program. We compared and contrasted these practices with
general management principles embodied in the Government Performance
and Results Act of 1993 and literature regarding effective management
practices at federal agencies.
In addition, to illustrate some of the ways in which other federal
agencies approach the management of their small business programs, we
obtained information on the practices of the small business offices at
three other agencies that either share certain characteristics with DOE
or that have agency components that share certain characteristics with
DOE: the National Aeronautics and Space Administration (NASA), the
Department of the Army (U.S. Army Corps of Engineers), and the
Department of Health and Human Services (Centers for Disease Control
and Prevention). Although DOE is unique in relying on facility
management contractors to accomplish much of its mission, the chosen
comparison agencies or agency components are similar enough to DOE to
provide useful insight within the context of their small business
programs. We selected these three agencies because each has annual
procurement activity on a scale as large, or larger, than the three DOE
program offices examined in this study, and each agency has
consistently been able to award a larger proportion of its procurement
dollars to small businesses than has DOE. Additionally, like DOE, these
agencies or their components that we visited must consider public
safety and national security concerns to execute sound procurement
decisions. Finally, these agencies or their relevant components have
missions that share similarities with those of the DOE program offices
we examined. For instance, both the U.S. Army Corps of Engineers and
DOE's Office of Environmental Management have environmental cleanup as
a key component of their mission. Basic scientific research is central
to the missions of both the Department of Health and Human Services'
Centers for Disease Control and Prevention and DOE's Office of Science.
NASA, like DOE, employs large firms to carry out facility management
contracts, although to a much lesser extent.[Footnote 9] We interviewed
small business, contracting, and procurement officials and staff from
these agencies, and reviewed program planning and guidance
documentation. We conducted our work between February 2005 and March
2006 in accordance with generally accepted government auditing
standards.
Results in Brief:
DOE has increased the total prime contracting dollars awarded to small
businesses since 2001 through three key efforts, although the
department still fell short of its goal in most years. First, DOE
increased the procurement opportunities available to small businesses.
Specifically, DOE identified larger procurements that could be split
and partially redirected from existing facility management contracts to
small businesses. DOE also set aside for small businesses many
nonfacility management contracts that were either new or up for
renewal. These nonfacility management contracts, however, represent a
declining share of total DOE procurements. Second, DOE expanded small
business development and outreach activities. For example, DOE revamped
its mentor-protégé program--which pairs an established contractor with
a less-experienced small business protégé--and participation increased
from 5 pairs in 2002 to 48 pairs in 2005, although just one of the
protégés has been awarded a prime contract to date. Third, DOE
strengthened management and oversight of its small business program.
For example, in 2002 DOE began to track, on a quarterly basis, the
proportion of total procurement dollars awarded by each program office
to small businesses. Collectively, these improvement efforts increased
awards to small business from about $589 million in 2001 to about $948
million in 2005. However, they have not been sufficient to enable DOE
to consistently meet its small business prime contracting goals. Since
2001, DOE has fallen short of its goal by at least $120 million every
year except 2003, when it exceeded its goal by $84 million. In 2005, it
appears that DOE missed its small business prime contracting goal of
5.5 percent of total procurement dollars by about $300 million,
although its estimated achievement of 4.15 percent would represent its
second highest performance since 2001. The three program offices we
reviewed--Office of Environmental Management, Office of Science, and
NNSA--are responsible for the vast majority of DOE's large facility
management contracts and control over 90 percent of DOE's procurement
dollars. However, in large part because of their reliance on facility
management contracts, these program offices account for less than half
of the nearly $1 billion in small business procurements that DOE made
in fiscal year 2005.
DOE faces two key management challenges to improving its small business
program practices. Addressing these challenges would bring DOE's small
business program more in line with practices of high-performing
organizations and with principles contained in the Government
Performance and Results Act. The key management challenges are as
follows:
* Although DOE establishes an annual small business prime contracting
goal, the department has not defined concrete steps that will enable it
to achieve this goal. DOE has identified a number of activities in its
small business strategic plan that it believes will contribute toward
achieving its goal, such as conducting the mentor-protégé program and
maintaining a procurement forecast. However, it has not defined what it
specifically expects to accomplish from each activity or established a
way to measure if these activities are indeed advancing DOE toward its
goal. For example, for the mentor-protégé program, the department has
not identified the number or value of small business prime contracts it
expects to result from the program.
* DOE does not use performance information to evaluate and improve
program performance. The department does collect some performance data,
but it does not collect sufficient information to allow it to
effectively assess its small business program efforts, identify
problems, and implement changes that could further increase small
business prime contracting over time. For example, DOE does not collect
data on the specific reasons that nonfacility management contracts may
not have been awarded to small businesses, even though department
policy requires that all such new contracts be reserved for small
businesses to the extent possible.
Although the manner in which federal agencies with similar missions or
with organizational components similar in mission to DOE carry out
their small business programs is comparable in several ways to DOE's
practices, there are important differences. Specifically, the agencies
differed substantially from DOE in their efforts to evaluate their
small business programs for effectiveness, to identify performance
problems, and to implement a program of corrective action to further
strengthen small business performance over the long-term. For example,
Department of the Army guidance requires that detailed performance
reviews of the U.S. Army Corps of Engineers and other component
offices' small business programs be completed once every 3 years.
Improvement plans are required to address any deficiencies. Similarly,
Health and Human Services provides for comprehensive evaluations of the
small business program at the Centers for Disease Control and
Prevention, and NASA evaluates the small business activities at the
agency's procurement centers. We did not evaluate the effectiveness of
these agencies' small business practices. However, over time, these
agencies awarded a greater share of their procurement dollars to small
businesses than DOE.
We are recommending that DOE take a more systematic approach to
managing its small business program to include the following: defining
the concrete steps DOE will take to achieve further progress toward its
annual goal; collecting relevant performance information to better
gauge the effectiveness of its efforts; and using performance
information to support program improvements, as needed.
DOE generally concurred with our findings and recommendations, but
expressed concern that, in comparing DOE to other federal agencies, we
did not fully appreciate the department's management and operating
contract business model. The report does recognize that the use of
large facility management contractors to perform much of DOE's work has
constrained the department's ability to contract with small businesses.
The report also recognizes that other federal agencies do not face a
similar constraint. We believe the comparisons we made between DOE and
other agencies are appropriate because we compared key management
practices of each agency's small business program, which are not
dependent on the particular business model used to accomplish the
agency's mission. DOE's written comments are reprinted in appendix II.
Background:
DOE has more than 50 major sites in 35 states where the department
carries out its varied missions, including developing, maintaining, and
securing the nation's nuclear weapons capability, cleaning up the
nuclear and hazardous wastes resulting from long-term weapons
production, and conducting basic energy and scientific research and
development. This work is overseen primarily by DOE's largest program
offices--the NNSA, the Office of Environmental Management, and the
Office of Science--and is primarily carried out though facility
management contracts. DOE has a workforce of 16,000 federal employees;
the department relies on the more than 100,000 employees of its
contractors to manage its facilities and achieve its missions.
DOE's contracts with small businesses occur in several different ways.
First, small businesses receive direct contracts from a portion of
DOE's procurement outlays that are not awarded as facility management
contracts. Second, small businesses may compete for and receive
facility management contracts. Historically, small businesses have not
performed these contracts, though in a few cases small businesses have
won such contracts after DOE identified ways to limit the contract's
scope of work. Third, small businesses receive subcontracts from DOE's
prime contractors. In 2004, approximately 17.5 percent of facility
management contract dollars went to small businesses as subcontracts.
Subcontracts, however, do not count toward achieving DOE's small
business prime contracting goal.
Advocacy responsibilities for small business contracting rest primarily
with a small business office--usually called the Office of Small and
Disadvantaged Business Utilization--at each executive-branch agency. In
general, officials in these small business offices are responsible for
negotiating an annual small business prime contracting goal with the
Small Business Administration (SBA), establishing each agency's small
business policy and guidance, coordinating agencies' small business
outreach efforts, and monitoring small business performance with
respect to the goal. Within DOE, the department's Office of Procurement
and Assistance Management and NNSA's Office of Acquisition and Supply
Management also play important supporting roles in promoting small
business prime contracting. These offices establish overall department
procurement policy and prepare more specific guidance to reflect
contracting requirements consistent with federal acquisition
regulations. These procurement offices also maintain data on DOE's
prime contracts, including annual obligations to small businesses, and
work with the Small Business Office staff to monitor small business
performance and implement small business policies. DOE's program
offices are responsible for identifying small business prime
contracting opportunities and providing contracting oversight. The SBA
calculates DOE's annual small business prime contracting achievement
using data from the Federal Procurement Data System-Next Generation, a
governmentwide procurement database that is administered by the General
Services Administration.
DOE Efforts to Increase Contracts with Small Businesses Have Had
Partial Success:
DOE's efforts to increase its prime contracts with small businesses
have increased the department's total expenditures on small business
prime contracts since 2001. However, the increases were not sufficient
to achieve the department's small business prime contracting goal in 4
of the past 5 years.
Key Efforts to Increase Small Business Contracts Focused on Expanding
Contracting Opportunities, Finding More Qualified Small Businesses, and
Improving Program Management and Oversight:
DOE's approach to increasing its prime contracting with small
businesses focused on three main areas: (1) identifying more
contracting opportunities for small businesses, (2) expanding small
business development and outreach activities to create a larger pool of
qualified small businesses, and (3) improving program management and
oversight.
Identifying More Contracting Opportunities for Small Businesses:
DOE's effort to increase the opportunities for small businesses to win
contracts with the department included restructuring or "breaking out"
portions of projects historically conducted by the department's
facility management contractors and redirecting that work to small
businesses, modifying procurement strategies to expand opportunities
for small businesses, and continuing to emphasize the award of
nonfacility management contracts to small businesses.
To redirect portions of projects traditionally performed under facility
management contracts, DOE's Office of Environmental Management
identified nine such projects that it believed could be reserved for
competition among small businesses as prime contracts. These prime
contracts, summarized in table 1, are collectively worth about $745
million, and many involve multiyear environmental cleanup,
construction, and facility operations activities that are essential to
the mission of this office. As of September 2005, the Office of
Environmental Management had successfully awarded seven of these
contracts and obligated about $266 million.[Footnote 10] In December
2005, this office awarded an eighth small business contract, the second
at Paducah, Kentucky. In December 2005, the Office of Environmental
Management cancelled the ninth contract, which involved the Fast Flux
Test Facility procurement at Hanford, Washington, due to budgetary
constraints and the need to focus resources on more important projects.
Table 1: Major Office of Environmental Management Procurements That
Redirect Work Traditionally Performed by Large Businesses with Facility
Management Contracts to Small Business Prime Contracts:
Dollars in millions.
Project and location: 222-S Lab, Hanford, WA;
Brief description of work: Analytic work on waste samples;
Contract value: $58.8;
Amount obligated[A]: $4.2.
Project and location: Columbus Closure Project, OH;
Brief description of work: Environmental cleanup;
Contract value: $42.1;
Amount obligated[A]: $34.6.
Project and location: Glass Waste Storage Building #2, Savannah River
Site, SC;
Brief description of work: Construction of waste storage facility;
Contract value: $63.2;
Amount obligated[A]: $59.3.
Project and location: Grand Junction Office Mission Support, CO;
Brief description of work: Technical, project management, and
administrative services;
Contract value: $159.5;
Amount obligated[A]: $120.1.
Project and location: Portsmouth Infrastructure, OH;
Brief description of work: Facility management contract for facility
operations services;
Contract value: $48.8;
Amount obligated[A]: $13.6.
Project and location: Portsmouth Remediation, OH;
Brief description of work: Facility management contract for
environmental cleanup;
Contract value: $141.3;
Amount obligated[A]: $28.2.
Project and location: Paducah Infrastructure, KY;
Brief description of work: Facility management contract for facility
operations services;
Contract value: $39.9;
Amount obligated[A]: $6.4.
Project and location: Paducah Remediation, KY;
Brief description of work: Facility management contract for
environmental cleanup;
Contract value: $191.6;
Amount obligated[A]: N/A[B].
Project and location: Fast Flux Test Facility, Hanford, WA;
Brief description of work: Deactivation, decontamination, and
decommissioning of reactor facility;
Contract value: N/A[C];
Amount obligated[A]: N/A[C].
Source: DOE.
[A] As of September 30, 2005.
[B] DOE awarded this contract in December 2005.
[C] DOE made an initial award of this contract in 2004 for $235
million. However, the award was protested and DOE withdrew the
solicitation. The procurement was subsequently cancelled in December
2005.
[End of table]
In comparison with the Office of Environmental Management, NNSA and the
Office of Science identified relatively fewer procurements that could
be redirected from their facility management laboratory contracts and
set aside for small businesses. NNSA and Office of Science procurement
officials said that redirecting work from facility management contracts
to small businesses was not a priority in their programs because
removing mission-related work from the contractors managing the
laboratories could diminish the department's ability to ensure the work
at these laboratories is effectively accomplished. However, these
officials were trying to identify mission-related work that could be
moved from facility management contracts to small business contracts
when a compelling "business case" could be made for doing so. For
example, in 2004 NNSA awarded a contract to a small business for
design, construction, and integration services for radiation sensors.
These services were previously provided under the Sandia National
Laboratories facility management contract. This award has an overall
value of $80 million, of which $71.5 million had been obligated through
the end of fiscal year 2005. In addition, NNSA and the Office of
Science recently collaborated with the Office of Environmental
Management to develop a small business information technology contract
to provide services at the three DOE facilities in Oak Ridge,
Tennessee. DOE plans to award this approximately $130 million contract
in fiscal year 2006. These information technology services are
currently being performed by three large businesses as subcontractors
to the facility management contractors at the Oak Ridge sites. Science
is also considering breaking out select small business subcontracts
from the Thomas Jefferson National Accelerator Facility contract and
awarding these as prime contracts.
To further expand opportunities for small businesses, DOE also modified
procurement strategies. Its two efforts in this area were led by the
Office of Environmental Management and NNSA. These two efforts were as
follows:
* In 2004, the Office of Environmental Management established
"indefinite delivery/indefinite quantity" contracts in which it
preapproved 8 large and 14 small businesses to provide services on
environmental cleanup and deactivation, demolition, and removal of
facilities on an as-needed basis. These contracts authorize a maximum
of $800 million in total contract task orders through 2009. Through
fiscal year 2005, almost $24 million in task orders had been issued,
all of which went to small businesses. Officials cited a variety of
possible reasons for the limited use of this contract mechanism so far,
including contract officers' unfamiliarity with implementation
procedures and security issues surrounding administration of the
contracts.
* An NNSA initiative--known as the "tri-lab initiative"--involved
combining procurements common to the Sandia, Lawrence Livermore, and
Los Alamos national laboratories, such as facility security,
maintenance services and computer hardware, and purchasing of goods and
services from small business suppliers. According to NNSA, most of the
targeted procurements were for support services, such as temporary
staff, rather than direct mission laboratory work. The three
laboratories initially estimated that as much as $187 million in
procurements could be redirected to small businesses in fiscal year
2005, with a goal of $300 million by 2007. However, before NNSA could
fully take advantage of any potential benefits, the initiative was
canceled. According to NNSA officials, the cancellation was primarily
due to congressional concerns regarding the potential impact on the
department's ability to ensure that the laboratories' projects are
effectively accomplished, as well as concerns that some small
businesses could lose existing laboratory subcontracts if NNSA awarded
the work as new prime contracts through the tri-lab initiative.
Finally, DOE's efforts to expand contracting opportunities included
continuing to emphasize the importance of directing nonfacility
management contracts to small businesses. DOE procurement officials
said that nonfacility management contracts issued by the department are
reserved for small businesses whenever possible. Exceptions would
involve situations in which only a large business supplier was
available, such as for utilities. Between fiscal years 2001 and 2004,
the percentage of these contracts awarded to small businesses increased
from 48.7 percent (753 out of 1,546 contracts) to 53.0 percent (831 out
of 1,569 contracts). In fiscal year 2004, small businesses received 61
percent ($282 million) of the total dollars spent on these new
nonfacility management contracts.
Expanding Small Business Development and Outreach Activities:
DOE has attempted to increase its use of small businesses by increasing
the pool of small businesses willing and able to provide goods and
services to the department. This effort has involved a variety of
business development and outreach activities, including establishing a
small business advisory team with participation by small businesses,
pairing large and small businesses as mentors and protégés to assist in
developing small businesses' capabilities, and periodically hosting
small business conferences to discuss upcoming contracting
opportunities and to help small businesses understand the intricacies
of the federal procurement process. DOE contends that many of these
activities will help to expand both prime contracts and subcontracts
with small businesses.
The extent to which these efforts contribute to DOE's small business
prime contracting achievements is generally unclear. For example,
regarding the pairing of small and large businesses in DOE's mentor-
protégé program, since 2002 the number of business pairs has increased
from 5 to 48, but only one participating small business has
subsequently received a prime contract from DOE. Similarly, while
attendance at DOE's annual small business conference has increased
since 2004, and the feedback DOE collects from participants is
generally positive, DOE does not know the extent to which the
conferences have led to small businesses receiving prime contracts.
In addition to these DOE-wide efforts managed by the Small Business
Office, the Offices of Environmental Management and Science, as well as
NNSA also pursue small business development and outreach activities,
including attending small business conferences, managing a mentor-
protégé program, and providing other training support for small
businesses. For example, NNSA conducts biweekly outreach to small
businesses by inviting interested small businesses to meet with NNSA
procurement officials to discuss their capabilities and learn of
upcoming procurement opportunities. NNSA has held 318 of these sessions
between March 2002 and January 2006. Nine small businesses attending
one or more of the sessions have obtained 25 DOE prime contracts worth
about $66 million. Also, Sandia National Laboratory, which primarily
conducts work for NNSA, runs its own mentor-protégé program that
intends to build the long-term capacity of small businesses.
Improving Program Management and Oversight:
To strengthen DOE's management and oversight of its small business
program, the Small Business Office took the following main actions:
* In 2002, it began quarterly reviews of the prime contracting
achievements of each program office. These reviews are intended to
track the department's progress toward meeting its overall small
business goal and to communicate results to program office officials
and the Secretary of Energy.
* In 2004, it attempted to improve coordination among the department's
small business, procurement, and program offices by establishing the
Advance Planning Acquisition Team. The team includes officials from
these DOE offices and intends to collectively review upcoming
procurements, identify potential small business contracting
opportunities, and exchange information on promising practices for
improving DOE's small business achievements.
* In 2004, it began to review all contracts over $3 million not
reserved for small businesses to determine if small business
opportunities had been adequately considered.
The department, however, does not collect data that indicate the extent
to which these efforts have directly or indirectly affected DOE's small
business prime contracting achievement. Therefore, the impact of these
efforts is unclear.
Despite Increasing Its Contracting with Small Businesses, DOE Prime
Contracting Achievement Continues to Fall Short of Its Annual Goal:
Despite DOE's efforts to strengthen its small business program, the
department has not achieved its small business prime contracting goal
in 4 of the past 5 years. Table 2 shows that DOE's procurement dollars
awarded to small businesses as prime contracts increased steadily
during the 5-year period, and the amount nearly doubled between fiscal
years 2001 and 2005.[Footnote 11] However, except for fiscal year 2003,
DOE failed to meet its annual small business prime contracting goal,
falling short by more than $120 million each year.
Table 2: DOE's Small Business Prime Contracting Goals and Achievements,
Fiscal Years 2001 through 2005:
Dollars in millions.
Goal;
2001: 5.00%;
2002: 3.70%;
2003: 3.70%;
2004: 5.06%;
2005[A]: 5.50%.
Achievement;
2001: 2.89%;
2002: 3.11%;
2003: 4.08%;
2004: 4.18%;
2005[A]: 4.15%.
Achievement;
2001: $588.6;
2002: $634.4;
2003: $904.2;
2004: $943.6;
2005[A]: $947.6.
Difference between goal and achievement;
2001: $429.7;
2002: $120.4;
2003: $84.2;
2004: $198.7;
2005[A]: $308.3.
Sources: GAO analysis of Fiscal Year 2001-2004 Small Business
Administration Goaling Achievement reports; 2005 data from Federal
Procurement Data System - Next Generation.
Notes: The fiscal year 2005 Federal Procurement Data System - Next
Generation data are preliminary, as of the issuance of this report, and
provide only an initial estimate of the department's fiscal year 2005
performance. The final Small Business Administration Goaling
Achievement report for FY05 is yet to be published. GAO has previously
questioned the reliability, accuracy and completeness of the Federal
Procurement Data System and the data of its predecessor system.
However, we determined that the federal data system's small business
contracting data, which are used by the Small Business Administration
to assess the prime contracting achievement of each federal agency,
were sufficiently reliable for purposes of this report. See appendix I
for further information on how we determined data reliability.
Percentages are of procurement dollars, and all dollars are constant
fiscal year 2005.
[End of table]
To some degree, DOE's small business prime contracting achievements
have been limited because the department's small business prime
contracting achievements occurred primarily from procurements that were
directed to nonfacility management contracts, which have been a
declining portion of DOE's overall procurement outlays. Between fiscal
years 2001 and 2005, more than 98 percent of the approximately $4
billion DOE obligated to prime contracts with small businesses went to
nonfacility management contracts. Only since fiscal year 2005 did DOE
direct facility management contracts to small businesses--$41.8 million
for infrastructure and remediation activities at Portsmouth and $6.4
million for infrastructure activities at Paducah. At the time of our
review, DOE had obligated $2.7 million to the Paducah remediation
facility management contract, which was awarded in December 2005.
During this time period, DOE's facility management contracts were
taking an ever-increasing share of total procurement dollars. In 2001,
DOE obligated about $14.8 billion to its facility management contracts,
which was about 80 percent of total procurements that year. In 2005,
DOE obligated $19.8 billion to its facility management contracts, which
was about 87 percent of the department's total procurement outlays.
In analyzing DOE's inability to meet its small business prime
contracting achievement goal, it is also worth noting that the program
offices we reviewed--the Offices of Environmental Management, and
Science, and NNSA--accounted for slightly less than half of the
approximately $948 million in small business prime contracting
achievements in fiscal year 2005 despite having responsibility for
almost 90 percent of DOE's total procurement dollars. According to
preliminary data from DOE's Small Business Office, in 2005 the Office
of Environmental Management directed about $198 million, or 2.9 percent
of its procurement dollars to small businesses; NNSA directed $237
million, or 2.6 percent; and the Office of Science directed about $30
million, or 1.1 percent.[Footnote 12] In contrast, more than half of
DOE's fiscal year 2005 contracting with small businesses originated
from the DOE offices that are collectively responsible for only 10
percent of the department's total procurement dollars. These offices
include, for example, the Office of Fossil Energy and Office of Energy
Efficiency and Renewable Energy. These smaller program offices within
DOE directed about $469 million, or 21 percent, of their procurement
dollars to small business prime contracts, slightly more than the
combined small business prime contracts at the Offices of Environmental
Management, and Science and NNSA. However, DOE's other program offices
are responsible for substantially fewer multimillion dollar facility
management contracts than the Offices of Environmental Management, and
Science and NNSA.
Two Key Management Challenges Hinder DOE's Efforts to Further Improve
Its Small Business Contracting Performance:
DOE faces two management challenges in further improving its small
business prime contracting performance. First, although DOE negotiates
an annual small business prime contracting goal, it has not identified
concrete steps--referred to as program objectives--that are expected to
contribute in a specific measurable way to achieving its goal. Second,
it does not use performance information to evaluate and improve program
performance. Both types of practices are commonly associated with high-
performing organizations and are consistent with principles contained
in the Government Performance and Results Act. More specific
information on these model practices and DOE's comparative practices
can be found in table 3.
Table 3: Practices of High-Performing Organizations Compared with DOE
Small Business Program Practices:
Suggested practice: Establish program goals;
Characteristics of practice: Goals should be measurable, specific, and
realistically represent something the organization can be expected to
achieve;
Why it is important: Focuses an organization's efforts on achieving
specific outcomes and allows an assessment of future performance
against the goals;
Extent to which DOE employs this practice: Fully: In accordance with
the Small Business Act, DOE negotiates an annual small business prime
contracting rate that takes into account agency mission, procurement
requirements, and past performance.
Suggested practice: Define program objectives;
Characteristics of practice: Program objectives can be thought of as
the concrete steps, path, or approach an organization intends to take
to reach a goal or goals. Objectives should be focused on the specific
results an organization wishes to achieve. They should also be
measurable so that progress on these objectives--success or failure--
can be easily determined;
Why it is important: Program objectives help lay out the strategy an
organization will employ to achieve its program goals. Having
objectives that are measurable allows management to assess the success
or failure of specific efforts to achieve its goals;
Extent to which DOE employs this practice: Partially: DOE has
identified a number of activities in its small business strategic plan
that it believes will contribute toward achieving its goal. However, it
has not laid out what it specifically expects to accomplish from each
activity or established a way to measure if these activities are indeed
advancing it toward its goal.
Suggested practice: Use performance information to evaluate and improve
program performance;
Characteristics of practice: Organizations should regularly collect and
analyze performance information to assess whether program activities
are having the desired results; Organizations should comprehensively
evaluate the performance of their programs on a periodic basis;
Why it is important: Timely collection and analysis of performance data
allows organizations to measure progress toward achieving their goals
and to adjust program activities and policies as necessary. In
addition, periodic comprehensive evaluations of program performance can
reveal systemic problems and promote continuous program improvement
over the long term;
Extent to which DOE employs this practice: Partially: The department
does collect some performance data, but does not collect sufficient
information to allow it to effectively assess its small business
program efforts, identify problems, and implement changes that could
further increase small business prime contracting over time.
Sources: GAO analysis of guidance published by the Governmental
Accounting Standards Board, the National Academy of Public
Administration, the IBM Center for the Business of Government, and
prior GAO reports regarding effective managing for results practices.
[End of table]
DOE Has Not Effectively Detailed How It Will Achieve Its Small Business
Prime Contracting Goal:
Although DOE negotiates a small business prime contracting goal each
year--5.5 percent in fiscal year 2005--DOE has not specified the
concrete steps the department will take to achieve its small business
prime contracting goal or how progress toward that goal can be
measured. In a literature review of the practices of high-performing
organizations, we found that such organizations often define specific
program objectives indicating how the organization intends to achieve
its goals. These objectives are measurable and are focused on the
specific results an organization wishes to achieve. Well-defined
objectives help an organization gauge its progress in achieving its
programmatic goal.
While DOE's small business strategic plan identifies a number of
activities--which the department refers to as "objectives"--that the
department believes will contribute toward achieving its goal, these
objectives do not lay out what it specifically expects to accomplish
from each activity or establish a way to measure if these activities
are indeed advancing it toward its goal. Among the "objectives" the
department has identified are maintaining a procurement forecast,
conducting a small business breakout study of facility management
contracts, and conducting a mentor-protégé program. DOE has not
indicated how these actions are intended to contribute to achieving its
small business prime contracting goal, and thus how the success of
these actions should be measured. For example, for the mentor-protégé
program, the department has not laid out the number or value of small
business prime contracts it expects to result from the program.
In addition, the department has not established program objectives for
those key departmental efforts holding the greatest promise to increase
the department's small business prime contracting. For example, DOE
currently sets aside prime contracts for small businesses from two
categories of procurements: nonfacility management contracts and
facility management contracts. Yet, the department has not specified
the extent to which each of these types of procurements should
contribute towards achievement of DOE's small business prime
contracting goal or how the success of DOE's efforts to set aside small
business contracts in these areas might be assessed. For example, 61
percent of obligations to new nonfacility management contracts went to
small businesses in 2004. However, only 28 percent of the total
obligations for nonfacility management contracts went to small
businesses. Whether or not DOE has been successful in reserving such
contracts for small businesses and whether the department's efforts
should be further improved are unclear. Defining an appropriate
objective regarding the small business awards for nonfacility
management contracts could increase DOE's understanding of its efforts
in this area and provide a much clearer means of assessing its
progress.
Similarly, the department has not established an objective for the
extent to which DOE might create small business opportunities from
facility management contracts. As discussed earlier, the proportion of
procurements associated with facility management contracts has been
increasing. Generally, the department has begun to recognize that to
further increase its small business prime contracting performance over
the long term, it may be necessary to increase the small business
opportunities redirected from facility management contracts.
Furthermore, Congress recently required DOE to study the feasibility of
changes to facility management contracts so that additional small
business prime contracting opportunities might be provided.[Footnote
13] To date, the Office of Environmental Management has led the
department's effort in redirecting such contracts to small businesses
by setting aside a number of small business opportunities culled from
facility management contracts. Other program offices have done so to a
lesser degree or have plans to do so in the future but have not yet
awarded those contracts. As DOE continues to consider what small
business opportunities it is reasonably able to draw from facility
management contracts, establishing a program objective would encourage
the department to maximize these opportunities.
DOE Does Not Use Performance Information to Evaluate and Improve
Program Performance:
DOE does not systematically analyze the performance of its small
business program to determine the effectiveness of specific activities
or policies in advancing its goal, although the department does collect
some performance information. DOE's main effort to collect and analyze
performance information consists of tracking the proportion of total
procurement dollars going to small businesses as prime and subcontracts
at both the agencywide level and the program office level. The prime
contracting data are tracked quarterly. Additionally, the Small
Business Office collects information on a few of its small business
development and support activities, such as attendance at and
participants' views on the quality of small business conferences. Also,
DOE's procurement office collects and tracks aggregate data on the
extent to which facility management and nonfacility management
contracts have been awarded to small businesses and whether such
contracts involve multiyear agreements.[Footnote 14]
DOE does not, however, collect sufficient information to provide the
department with insight on whether or how specific policies or
processes should be changed to further increase small business prime
contracting. For example, as noted earlier, DOE's policy is to set
aside for small businesses all new nonfacility management contracts to
the extent possible; in fiscal year 2004, about half of all new
nonfacility management contracts were awarded to small businesses and
half were not. However, the department does not require procurement
staff to report the reasons that contracts have not been awarded to
small businesses. The Federal Procurement Data System allows agencies
to report several reasons for nonawards that include the following: no
known small business source; a small business was solicited but did not
make an offer; and a known small business source existed, but no offer
was solicited. Such information might help DOE assess if staff are
having difficulty identifying small businesses capable of performing
DOE contracts, if small businesses are having problems preparing
offers, or if time constraints are limiting staff efforts to solicit
offers from small businesses, for example. A senior procurement analyst
with DOE's Office of Procurement and Assistance Management said the
department does not collect this type of information because it has not
viewed it as useful. However, high-performing organizations regularly
collect and analyze performance data to develop information on the
effectiveness of their efforts--determining whether or not these
efforts are achieving the desired results.
In addition, many high-performing organizations also conduct periodic
program reviews or audits to identify systemic problems and determine
what adjustments to policy or practice should be made to improve
performance over the long run. While the department does conduct some
limited assessments of the small business efforts carried out by the
individual program offices, these assessments do not routinely result
in documented plans for improved long-term performance. For example,
DOE's procurement office requires program offices to periodically
review compliance with overall federal acquisition regulations,
including specific requirements regarding small business prime
contracting. But according to the manager of this effort, these limited
compliance reviews have not identified problems with any program
office's small business practices that have required corrective action.
In addition, DOE's Small Business Office conducts an informal
assessment of a program office's efforts to meet its small business
prime contracting goal when that office does not achieve its goal.
However, the Small Business Office officials said they tend to focus on
near-term obstacles that the program office faces in awarding small
business contracts rather than on systematically evaluating the program
office's management of its small business prime contracting efforts.
Problems identified often include such things as bid protests and
delayed appropriations that impede the award of anticipated small
business contracts. Similarly, any planned corrective action tends to
focus on a program office's ability to identify additional contracting
opportunities for small businesses in the near-term, rather than on
programmatic changes that might improve performance over the long-term.
Furthermore, because the assessment is informal, it is not documented,
leaving the Small Business Office without a written plan that can be
used to hold a program office accountable for achieving results. Thus,
when the department's three largest program offices appeared unable to
meet their small business prime contracting goals in fiscal year 2005-
-leaving DOE short of its 5.5 percent small business goal--the
department had little information to fully account for the shortfall or
systematically determine a course of possible corrective action to make
program improvements.
Other Federal Agencies Use Formal Program Evaluation to Guide Changes
in Their Small Business Programs:
The small business management practices employed by federal agencies
having a mission or agency component with a mission similar to DOE's
provide examples of strategies for small business program evaluation
and continuous improvement. Unlike at DOE, each agency is required to
use performance information gained from periodic program reviews to
help identify and direct program improvement efforts. We did not assess
the specific small business practices employed by these agencies to
determine if they were effective or the impact these practices may have
had upon their small business prime contracting.[Footnote 15] However,
over time, these agencies and the components we visited have awarded a
greater share of their procurement dollars to small businesses and more
often met their prime contracting goals than has DOE.[Footnote 16]
In general, the small business programs at the three agencies we
visited carry out activities similar to those conducted by DOE. As with
all federal agencies, procurements are subject to the requirements of
the Small Business Act and the Federal Acquisition Regulation, which
together require small business contracting procedures and set-asides
meant to ensure small businesses are afforded maximum practicable
opportunities for federal prime contracts. As such, each small business
office has a role in articulating and establishing agency small
business contracting policy, as well as conducting small business
outreach and development activities. As at DOE, these agencies, their
components that we visited, or both, also promote the use of small
businesses among agency contracting and procurement staff, train agency
staff on federal and agency small business contracting requirements,
maintain databases of potential small business vendors, and track and
report small business accomplishments, periodically reporting results
to senior agency officials.
In contrast to DOE, however, NASA, the Department of the Army, and the
Department of Health and Human Services use formal program evaluation
to guide programmatic changes. In conjunction with the Office of
Procurement, the NASA small business office performs a comprehensive
review of NASA's procurement offices on a rotating three-year
basis.[Footnote 17] The purpose of the audit is to ensure that the
small business program is being appropriately implemented and to bring
to management's attention issues that hinder progress toward agency
goals. This review also examines how well the small business goals are
being met, what the major impediments to small business utilization
are, and what steps can be taken to improve small business usage within
the procurement center. A recent review of NASA's Kennedy Space Center
found that occasionally small business specialists found it difficult
to balance their procurement and small business work duties and
recommended some organizational changes that would help staff surmount
such difficulties. Another recent review of the Goddard Space Flight
Center identified a strained relationship between the SBA's procurement
center representative, who assesses NASA procurements for small
business opportunities, and procurement center staff. The review
recommended mediation from the Small Business Administration regional
office to improve that relationship. In addition, the Goddard review
also included a recommendation to further reinforce the importance of
small businesses to NASA by having newly-hired staff and some others
participate in an internal training course sponsored by the NASA small
business office. According to NASA small business officials, this
course is intended to show that the use of innovative and technically
competent small businesses make business sense for NASA, regardless of
the particular small business contracting goal, and can contribute
substantially to the agency's ability to achieve its scientific
mission. The Director of NASA's small business office said that one of
the main functions of his office staff is ensuring that program and
procurement officials throughout the agency understand the business and
mission benefits of contracting with small businesses.
Similarly, the Department of the Army is subject to an annual small
business program review by the Department of Defense (DOD) small
business office, in which the Army must be evaluated on a number of
factors that are both qualitative and quantitative, such as whether the
organization has been able to meet its internal prime contracting goal,
whether its performance has improved over the prior year, and the
quality of organization's small business improvement plan. If DOD
officials are unsatisfied with the performance rating earned by the
Army, the head of the organization may be required to implement a
performance improvement plan, which must be reviewed with senior
department officials in the Office of the Under Secretary for
Acquisition, Technology, and Logistics. Army officials said they
believe that elevating these concerns to a higher department level
helps ensure problems are corrected. In addition, the Army is required
to outline a minimum of three program improvement initiatives it
intends to pursue during the year. These initiatives must include
implementation milestones and criteria for assessing whether the
initiatives have been successful. For example, in 2004, the Army
identified an initiative to establish the policies and procedures of
the Army-managed mentor-protégé program. This initiative ultimately led
to a number of policy changes, an independent Army mentor-protégé
program, and a workshop to help small businesses understand how to
develop a formal mentor-protégé agreement with a DOD prime contractor.
Although the Army requires its subordinate organizations to report
small business prime contracting progress annually, which is
substantially less often than such performance is tracked at DOE, the
Army evaluates the small business program performance of each
subordinate Army organization, including the U.S. Army Corps of
Engineers, by conducting comprehensive performance audits at least once
every 3 years. These comprehensive audits of Army small business
programs are intended to generate a program improvement plan to address
any deficiencies identified during the audit. Deficiencies that require
corrective action must be reported to the Secretary of the Army. Army
officials said they believe that yearly performance reviews and a
periodic comprehensive evaluation together help ensure that needed
programmatic changes are implemented.
The Department of Health and Human Services also employs program
evaluations with the aim of producing small business program
improvements. Health and Human Services is in the initial stage of
using the agencywide balanced scorecard, an evaluation framework Health
and Human Services uses to assess its performance in a number of
diverse areas, to periodically evaluate its small business program.
Part of this effort includes surveying a wide range of small business
program stakeholders--agency employees, customers, and vendors--to
determine both the quality and quantity of services provided not only
by Health and Human Services' small business office, but also by the
small business specialists assigned to operational divisions, such as
the Centers for Disease Control and Prevention.[Footnote 18] To
determine the effectiveness of the agency's small business program,
these surveys target questions for the different stakeholders. For
instance, employees of the operational divisions are asked how well
small business specialists are supporting their procurement efforts,
whether they understand small business contracting requirements, and
how much the small business specialists are involved in advanced
acquisition planning, among other things. The agency also surveys
potential small business contractors on the quality of support they
receive from small business specialists, in particular whether staff
has sufficiently explained how to do business with Health and Human
Services, whether they have been adequately informed of contracting
opportunities, and whether they have received help resolving problems
with solicitation issues. Health and Human Services intends to
aggregate results and provide a descriptive statistical analysis, using
the data to drive the small business program's continuous improvement
efforts. For example, the results are intended to help determine if
additional program oversight, such as program audits or on-site
monitoring, is necessary. Health and Human Services intends for this
evaluation to be conducted once every 2 years. Each operational
division, including the Centers for Disease Control, must subsequently
prepare a summary report that identifies needed changes, a plan to
address any performance areas requiring improvement, and target dates
for completing improvements. This report must be submitted to Health
and Human Services' management and appropriate agency stakeholders.
Conclusions:
DOE has made progress since 2001 not only in increasing the total
dollars it awards to small businesses, but also in increasing the share
of its procurement dollars awarded to such businesses. Nonetheless, it
has been able to achieve its annual small business prime contracting
goal just once in the last 5 years. DOE's performance as well as its
future potential in this area is clearly constrained by the
department's traditional reliance on a limited group of large firms and
universities to manage high-cost projects in which public safety and
national security are important concerns. Moreover, the share of the
department's procurement dollars going to such projects is increasing,
whereas the share going to projects more commonly performed by small
businesses is declining. These circumstances create hurdles for DOE
that other federal agencies do not face.
In spite of these circumstances, DOE has made substantial efforts to
improve its small business prime contracting performance. However, the
department has not accompanied these efforts with a clear understanding
of how they affect prime contracting performance, which efforts are
working well and which are not, and what changes might be made to
improve the effectiveness of these efforts. If DOE can combine its
small business improvement efforts with a clear strategy for achieving
its annual goal, with performance information that indicates its
efforts are effective, and with program evaluations that help to
identify problems and lead the department to address them, DOE can more
credibly demonstrate that--even if it continues to fall short of its
prime contracting goal---it has done all it possibly can to give small
businesses the maximum practicable opportunity to contract with the
department.
Recommendations for Executive Action:
To improve DOE's management of its small business prime contracting
program and to help ensure that small businesses receive the maximum
practicable opportunity for DOE prime contracts, we recommend the
Secretary of Energy direct the Office of Small and Disadvantaged
Business Utilization, the Office of Procurement and Assistance
Management, and the NNSA Office of Acquisition and Supply Management to
jointly establish a systematic, organized, and disciplined approach to
achieving the department's small business goal. Such an approach should
include the following three steps:
* Define small business program objectives that collectively identify
the steps or approach DOE intends to take to reach its annual prime
contracting goal. These objectives should focus on the specific results
the department intends to achieve, should clearly contribute directly
to DOE's prime contracting performance, and should be measurable so
that progress can be determined.
* Identify, collect, and analyze performance information that will
allow the department to determine whether the small business program
activities it carries out are achieving the desired results.
* Periodically conduct a comprehensive evaluation of the department's
and program offices' small business programs to determine if changes
are needed and use these assessments to guide improvement efforts.
Agency Comments and Our Evaluation:
We provided a draft of this report to the Department of Energy for
review and comment. In written comments, the Director of the Office of
Small and Disadvantaged Business Utilization stated that DOE concurred
with findings and recommendations and was taking steps to further
improve its small business efforts. For example, DOE stated it would
take further steps to identify the approach it will take to reach its
annual prime contracting goal, to better assess the effectiveness of
its existing small business efforts and identify areas of improvement,
and conduct periodic evaluations of the department's small business
programs. However, DOE expressed concern that we did not fully
appreciate the department's management and operating contract business
model, especially in making comparisons to the small business programs
at other federal agencies. The report does recognize that the use of
large facility management contractors to perform much of DOE's work has
constrained the department's ability to contract with small businesses.
The report also recognizes that other federal agencies do not face a
similar constraint. We believe the comparisons we made between DOE and
other agencies are appropriate because we compared key management
practices of each agency's small business program, which are not
dependent on the particular business model used to accomplish the
agency's mission. Furthermore, in selecting the three federal agencies
to contrast with DOE's small business program, our intent was to
provide information on specific small business practices that differed
somewhat from DOE's own practices and that might provide examples for
DOE as it continues its improvement efforts. DOE also provided
technical comments on the draft report, which we incorporated as
appropriate.
We are sending copies of this report to the Secretary of Energy and the
Administrator of the NNSA. We will also make copies available to others
upon request. This report will be available at no charge on the GAO Web
site at http://www.gao.gov.
If you or your staff have any questions about this report, please
contact me at (202) 512-3841 or aloisee@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Staff who made key contributions to this
report are listed in appendix III.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to (1) provide an update on the Department of
Energy's (DOE) key efforts to increase small business prime contracting
opportunities and the results of these efforts to date and (2) identify
the management challenges DOE faces in improving its small business
prime contracting performance. In addition to these objectives, we are
providing information on the management of small business programs by
other federal agencies that either share certain characteristics with
DOE's largest program offices or that have components that share
certain characteristics with these offices.
To conduct our work, we interviewed DOE headquarters and program office
officials,as well as representatives from the Small Business
Administration (SBA), and collected and analyzed data from federal and
DOE procurement databases. We also interviewed officials from the small
business offices at the Department of Defense, the Department of the
Army, the Department of Health and Human Services, and the National
Aeronautics and Space Administration (NASA).
To gain an understanding of DOE's key small business management efforts
and results to date, we obtained and reviewed DOE policy guidance and
management directives concerning small business prime contracting,
including internal memoranda, small business and procurement guidance,
agencywide and program-specific small business plans, budget documents,
and other related documents. To further gain an understanding of the
DOE Small Business Office and Office of Procurement and Assistance
Management roles and responsibilities with regard to small business
prime contracting, we reviewed the Federal Acquisition Regulation, as
well as the DOE-specific supplement to these regulations. We also
interviewed DOE officials in the Small Business Office and small
business officials from the department's program offices, as well as
officials in the Office of Procurement and Assistance Management and
their counterparts at the National Nuclear Security Administration
(NNSA). We also interviewed officials at SBA to learn about federal
small business policy, how small business goals are established with
the federal agencies, how they ensure the federal government meets
these goals, and what role they have in overseeing small business
activities nationwide.
To determine DOE's small business prime contracting achievement for
fiscal years 2001 through 2004, we reviewed SBA's federal goals report.
To determine DOE's small business prime contracting achievement for
fiscal year 2005, and to determine expenditures to date toward specific
contracts, we relied on the Federal Procurement Data System--Next
Generation (FPDS-NG),[Footnote 19] the federal government's repository
of information regarding the nature and value of federal procurement
actions. This database contains detailed information on government
contract actions over $25,000 and summary data for procurements of less
than $25,000. We have previously issued reports critical of the
reliability, accuracy, and completeness of FPDS-NG data and the data of
its predecessor system[Footnote 20] and remain concerned about some
aspects of the data system. However, based on the following measures,
we determined that the data of interest were sufficiently reliable for
the purposes of this report. We interviewed DOE officials and officials
from the General Services Administration, the agency responsible for
the FPDS-NG system, to determine the steps taken to ensure accuracy and
completeness of procurement data in FPDS-NG. In addition to FPDS-NG, we
also used data taken from a DOE-specific procurement database, called
the Procurement and Assistance Data System and maintained by DOE's
Office of Procurement and Assistance Management, to determine fiscal
year 2005 prime contracting achievements for DOE's largest program
offices: the Office of Environmental Management, the Office of Science,
and NNSA. As appropriate, we converted dollar values to constant 2005
dollars using Gross Domestic Product price indices from the Bureau of
Economic Analysis.
To identify the main challenges DOE faces in improving its small
business prime contracting performance, we reviewed the management
practices of DOE's small business program and compared these against
established management principles identified in select literature from
leading organizations on effective management practices at federal
agencies. For example, we reviewed guidance published by the
Governmental Accounting Standards Board, the National Academy of Public
Administration, and the IBM Center for the Business of Government,
regarding effective management practices. We also reviewed prior GAO
reports concerning managing for results, as well as the Government
Performance and Results Act of 1993. We also reviewed program guidance,
management directives, including DOE internal guidance entitled
Managing Critical Management Improvement Initiatives, and program
performance plans to determine the current practices supporting the DOE
small business program. To gain a further understanding of DOE's small
business management efforts, we also interviewed DOE Small Business
Office officials and staff, and DOE Procurement Office officials.
To provide information on how other federal agencies address small
business program management challenges, we obtained information on the
practices of the small business offices of three other agencies that
either share certain characteristics with DOE or have component
organizations that share characteristics with DOE: the National
Aeronautics and Space Administration, the Department of the Army (U.S.
Army Corps of Engineers), and the Department of Health and Human
Services (Centers for Disease Control and Prevention). We selected
these agencies because each has annual procurement activity on a scale
as large as or larger than the three DOE offices examined in this study
and each agency has been able to award a larger share of its
procurement dollars to small business than has DOE. Additionally, like
DOE, these agencies must consider public safety and national security
concerns to execute sound procurement decisions. See table 4 for a
comparison of each agency's 2004 total procurements and small business
prime contracting achievement information. Finally, these agencies were
chosen to reflect the complexity of the varied missions at DOE. Both
the U.S. Army Corps of Engineers and DOE's Office of Environmental
Management have environmental cleanup as a key component of their
missions; scientific research conducted by the Centers for Disease
Control and Prevention is similar in scope and complexity to that
conducted by DOE's Office of Science; and both the NNSA and NASA have
highly technical and complex missions.
Table 4: Comparison of DOE, Department of Defense, Health and Human
Services, and National Aeronautics and Space Administration Small
Business Prime Contracting Performance, Fiscal Year 2004:
Dollars in billions.
Department of Energy;
Total procurements: $22.0;
Total small business prime contracting: $0.9;
Small business prime contracting achievement: 4.2%;
Small business prime contracting goal: 5.1%.
Department of Defense;
Total procurements: $210.7;
Total small business prime contracting: $46.9;
Small business prime contracting achievement: 22.3;
Small business prime contracting goal: 23.0.
Department Of the Army[A];
Total procurements: $55.5;
Total small business prime contracting: $15.5;
Small business prime contracting achievement: 27.9;
Small business prime contracting goal: 26.6.
U.S. Army Corps of Engineers[A];
Total procurements: $8.8;
Total small business prime contracting: $3.5;
Small business prime contracting achievement: 39.5;
Small business prime contracting goal: 40.4.
Health and Human Services;
Total procurements: $7.9;
Total small business prime contracting: $2.3;
Small business prime contracting achievement: 29.6;
Small business prime contracting goal: 30.3.
Centers for Disease Control and Prevention[A];
Total procurements: $0.98;
Total small business prime contracting: $0.13;
Small business prime contracting achievement: 13.6;
Small business prime contracting goal: 30.3.
National Aeronautics and Space Administration;
Total procurements: $12.5;
Total small business prime contracting: $1.8;
Small business prime contracting achievement: 14.5%;
Small business prime contracting goal: 16.2%.
Sources: GAO analysis of procurement and contracting data provided by
federal agencies reviewed and SBA 2004 goaling report.
[A] SBA only reports data for the totality of agency procurements. The
data for the Department of the Army (U.S Army Corps of Engineers), and
the Centers for Disease Control and Prevention were provided by
department officials.
[End of table]
To provide information on the small business program management and
oversight at these agencies, we obtained and reviewed documentation of
agency-specific procurement regulations, small business and procurement
policy guidance, management memoranda, small business strategic plans,
budget documents, and other related documentation. In addition, we
interviewed cognizant officials at each agency concerning this
information. We did not assess the specific small business practices of
these agencies to determine if they were effective. Instead, we
obtained information on small business program activities to identify
practices that somewhat differed from DOE's practices and that could
serve as examples DOE might want to consider as it further seeks to
improve its prime contracting performance. Although the examples we
highlight in this report are consistent with established management
principles, we did not determine if these practices, as implemented by
the federal agencies we visited, have had a direct impact on their
small business prime contracting.
The Department of Defense maintains a small business office for each
major component of the agency, and the operations of each are overseen
by the Department of Defense's small business office. Therefore, we
interviewed small business officials in the small business offices at
the Department of Defense, the Department of the Army, and the U.S.
Army Corps of Engineers. The Department of Health and Human Services,
in contrast, has a central agencywide small business office that is
supported by a small business specialist in each of its 11 operating
divisions, such as Centers for Disease Control and Prevention.
Therefore, we interviewed small business officials from the
department's small business office, as well as the small business
specialist and procurement officials at the Centers for Disease
Control. NASA's small business office is similarly centralized, so we
conducted interviews with officials from this office only.
We conducted our work between February 2005 and March 2006 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the Department of Energy:
Department of Energy:
Washington, DC 20585:
April 3, 2006:
Mr. Gene Aloise:
Director:
Natural Resources and Environment:
U.S. Government Accountability Office:
701 56th Avenue, Suite 2700:
Seattle, Washington 98104:
Dear Mr. Aloise:
The Department of Energy (DOE) appreciates the opportunity to provide
its management response to the Government Accountability Office (GAO)
draft report titled, DOE Contracting, Improved Program Management Could
Help Achieve Small Business Goal (GAO-06-501). We acknowledge the GAO's
recognition of the many successful and important small business
initiatives the Department has undertaken. However, we continue to be
concerned with the GAO's lack of appreciation of the Department's
management and operating (M&O) contract business model and its
comparison to other Federal agencies. This M&O business model has been
utilized successfully for over fifty years to meet the Department's
national security, environmental, and scientific missions. In addition,
no other agency has the unique responsibility to manage the Nation's
nuclear weapons and supply chain infrastructure, including handling
special nuclear materials and the associated essential safety and
security requirements.
The enclosed "Response to Recommendations for Executive Action" should
be included in the appendix to the final report. As regards the
specific recommendations of the report, I want to assure you that the
Office of Small and Disadvantaged Business Utilization, the Office of
Procurement and Assistance Management, and the NNSA Office of
Acquisition and Supply Management are already working together on
behalf of small business, and we will continue to do so in order to
establish a systematic, organized, and disciplined approach to
achieving the Department's small business goals.
In closing, the significance of DOE's contribution to the small
business economic base of the Nation, when considered beyond the single
data point of goal achievement, is impressive and noteworthy. DOE has
awarded over $1.5 billion contracting dollars over the last two fiscal
years to small businesses in the United States. Those dollars provide a
meaningful and sustained economic boost to the local economies where
they operate, providing hundreds of jobs in areas of the country where,
absent a DOE presence, economic growth would be hindered.
Should you have any questions regarding the DOE response, please
contact me at (202) 586-8383.
Sincerely,
Signed by:
Theresa Speake:
Director:
Office of Small and Disadvantaged Business Utilization:
Enclosures:
Response to Recommendations for Executive Action:
To improve DOE's management of its small business prime contracting
program and to help ensure that small businesses receive the maximum
practicable opportunity for DOE prime contracts, we recommend the
Secretary of Energy direct the Office of Small and Disadvantaged
Business Utilization, the Office of Procurement and Assistance
Management, and the NNSA Office of Acquisition and Supply Management to
jointly establish a systematic, organized and disciplined approach to
achieving the department's small business goal. Such approach should
include the following steps:
1) Define small business program objectives that collectively identify
the steps or approach DOE intends to take to reach its annual prime
contracting goal.
The Department will re-examine, and attempt to better articulate
through existing planning and policy documents, those concrete steps it
is already taking to reach its prime contracting goal, as well as to
identify and initiate additional ones. DOE has in place a number of
significant steps to optimize its small business program performance,
including a Department-wide strategic plan for small business programs.
Additional steps include an annual call to program and field offices to
prospectively identify small business opportunities that may be awarded
to small business, the publication of an annual forecast of contracting
opportunities, the negotiation of departmental goals with the SBA, the
negotiation of goals and the tracking and analysis of achievements on a
quarterly basis by program activity and contracting office, and
enactment of policy improvements to ensure that small business
opportunities are identified early in the acquisition cycle. DOE will
also continue to target small businesses for participation in
acquisitions under the General Federal Supply Schedules.
2) Identify, collect and anal performance information that will allow
the Department to determine whether small business program activities
it carries out are achieving the desired results.
DOE will continue to identify, collect and analyze performance
information to determine whether DOE's small business program
activities achieve desired results. The Department's ultimate objective
is to better assess the effectiveness of existing efforts, while
identifying additional areas for improvement. DOE will continue to
track and evaluate the performance of its program offices in achieving
their individual goals as well as the department's overall small
business goals.
3) Periodically conduct a comprehensive evaluation of the Department's
and program offices' small business programs to determine if changes
are needed and use these assessments to guide improvement efforts.
We concur that a periodic comprehensive evaluation of the small
business programs should be conducted to support program improvements
as needed.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise (202) 512-3841:
Staff Acknowledgments:
In addition to the individual named above, William R. Swick, Assistant
Director; Doreen Feldman; Kevin Jackson; Carolyn Kirby; Michael L.
Krafve; Harry Medina; Dominic Nadarski; Cynthia Norris; John W.
Stambaugh; Stan Stenersen; and Virginia Vanderlinde made key
contributions to this report.
FOOTNOTES
[1] The Small Business Administration (SBA) defines small businesses as
enterprises that (1) are independently owned and operated; (2) are not
dominant in their field of operation; and (3) meet SBA-defined criteria
for company size and sales volume, which vary depending on industry
type. SBA uses the term "other than small business" for all entities
that are not small businesses. For the purposes of this report, a large
business fits the SBA definition of "other than small business."
[2] See, e.g., 15 U.S.C. § 631(a) (declaration of policy set out in the
Small Business Act).
[3] 15 U.S.C. § 644(g). Prime contracts are direct contracts between
the government and a contractor.
[4] Certain categories of procurements are excluded from this
requirement. These include federal agencies that fund contracts
primarily with funds from agency-generated sources (e.g., the U.S.
Postal Service) and contracts not under the Federal Acquisition
Regulation (e.g., the Federal Aviation Administration).
[5] NNSA is a separately organized agency within DOE with its own
procurement organization and program offices. For purposes of this
report, NNSA is referred to as a "program office," as are DOE's Office
of Environmental Management, Office of Science, and other program-based
organizational elements.
[6] A subcontract is any contract entered into by a prime contractor or
subcontractor to provide supplies and/or services in support of a prime
contract or subcontract.
[7] The Office of Federal Procurement Policy within the Office of
Management and Budget issues policy letters and is responsible for
resolving any disagreements between the Small Business Administration
and federal agencies on small business prime contracting goals.
[8] GAO, Department of Energy: Achieving Small Business Prime
Contracting Goals Involves Both Potential Benefits and Risks, GAO-04-
738T (Washington, D.C.: May 18, 2004).
[9] GAO has previously reported on aspects of NASA's small business
prime contracting performance. See GAO, Federal Procurement: Trends and
Challenges in Contracting with Women-Owned Small Businesses, GAO-01-346
(Washington, D.C.: Feb. 16, 2001).
[10] Although the total award value of these contracts is about $745
million, the SBA uses annual obligations in its measure of DOE's small
business achievements. Award value often spans multiple years over the
life of a contract.
[11] Unless otherwise specified, all dollar values in the remainder of
this section are reported as constant 2005 dollars.
[12] The Federal Procurement Data System does not report achievement
data by DOE program office. The achievements by program office reported
here are estimated from DOE's internal data system, and totaled $934
million in September 2005, the most recent data available. This total
differs slightly from the $947.6 million in small business achievements
calculated by the federal data system.
[13] Section 6022 of the 2005 Emergency Supplemental Appropriations Act
for Defense, the Global War on Terror, and Tsunami Relief (Pub. L. No.
109-13) requires the SBA administrator, the Chief Counsel for Advocacy
of the Small Business Administration, the chairman of the Defense
Nuclear Facilities Safety Board, the Secretary of Energy, and the NNSA
administrator to jointly conduct a study regarding the feasibility of
possible changes to management and operating contracts (referred to as
facility management contracts in this report) and other management
contracts within DOE to encourage new opportunities for small
businesses to increase their role as prime contractors. In conducting
the study, they are required to jointly consider the need for sound
management practices at facilities managed by prime contractors,
safety, security, and necessary oversight of facilities, and the
resources required to implement findings of the study. According to SBA
officials, at the time of our review, the study was still under way,
and a report date had not been determined.
[14] DOE's procurement office also has a balanced scorecard program
intended to assess the efficiency and effectiveness of the department's
overall procurement program. The balanced scorecard is a conceptual
framework intended to translate an organization's vision and goals into
a set of performance indicators that measure progress toward these
goals. Through the balanced scorecard, an organization monitors both
its current performance and its efforts to improve processes. The
balanced scorecard does not, however, include a specific effort to
assess the effectiveness of the small business program.
[15] For further information on our work at these federal agencies,
including the limitations of the data and information we obtained,
please refer to appendix I.
[16] Because these goals are negotiated at the parent organization
level, the Department of the Army does not directly negotiate a goal
with the SBA. However, Army and the U.S. Army Corps of Engineers both
have consistently exceeded the goal negotiated between SBA and the
Department of Defense, its parent department.
[17] This NASA review is called the "Procurement Management Survey
Report."
[18] According to the director of Health and Human Services' s small
business office, these activities are the result of departmental small
business policies and are required not only of the Centers for Disease
Control, but of other operational divisions as well.
[19] For a discussion of this system, see: GAO, Improvements Needed to
the Federal Procurement Data System-Next Generation, GAO-05-960R
(Washington, D.C.: Sept. 27, 2005).
[20] See GAO, Contract Management: Reporting of Small Business Contract
Awards Does Not Reflect Current Business Size, GAO-03-740T (Washington,
D.C.: May 7, 2003) and GAO, Reliability of Federal Procurement Data,
GAO-04-295R (Washington, D.C.: Dec. 30, 2003).
GAO's Mission:
The Government Accountability Office, the investigative arm of
Congress, exists to support Congress in meeting its constitutional
responsibilities and to help improve the performance and accountability
of the federal government for the American people. GAO examines the use
of public funds; evaluates federal programs and policies; and provides
analyses, recommendations, and other assistance to help Congress make
informed oversight, policy, and funding decisions. GAO's commitment to
good government is reflected in its core values of accountability,
integrity, and reliability.
Obtaining Copies of GAO Reports and Testimony:
The fastest and easiest way to obtain copies of GAO documents at no
cost is through the Internet. GAO's Web site ( www.gao.gov ) contains
abstracts and full-text files of current reports and testimony and an
expanding archive of older products. The Web site features a search
engine to help you locate documents using key words and phrases. You
can print these documents in their entirety, including charts and other
graphics.
Each day, GAO issues a list of newly released reports, testimony, and
correspondence. GAO posts this list, known as "Today's Reports," on its
Web site daily. The list contains links to the full-text document
files. To have GAO e-mail this list to you every afternoon, go to
www.gao.gov and select "Subscribe to e-mail alerts" under the "Order
GAO Products" heading.
Order by Mail or Phone:
The first copy of each printed report is free. Additional copies are $2
each. A check or money order should be made out to the Superintendent
of Documents. GAO also accepts VISA and Mastercard. Orders for 100 or
more copies mailed to a single address are discounted 25 percent.
Orders should be sent to:
U.S. Government Accountability Office
441 G Street NW, Room LM
Washington, D.C. 20548:
To order by Phone:
Voice: (202) 512-6000:
TDD: (202) 512-2537:
Fax: (202) 512-6061:
To Report Fraud, Waste, and Abuse in Federal Programs:
Contact:
Web site: www.gao.gov/fraudnet/fraudnet.htm
E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470:
Public Affairs:
Jeff Nelligan, managing director,
NelliganJ@gao.gov
(202) 512-4800
U.S. Government Accountability Office,
441 G Street NW, Room 7149
Washington, D.C. 20548:
