Contract Management
Postal Service's National Office Supply Contract Has Not Been Effectively Implemented Gao ID: GAO-03-230 January 17, 2003Over the past 2 years, the Postal Service has experienced growing financial difficulties. In an effort to transform the organization to reduce costs and increase productivity, the Postal Service awarded a national-level office supply contract to Boise Corporation. In addition, the Postal Service required Boise to submit a subcontracting plan, which outlines how small, minority-, and woman-owned businesses will be reached through the contract. GAO was asked to assess the status of the Postal Service's implementation of the Boise contract and Boise's achievement of its subcontracting plan. GAO also reviewed the extent to which the Postal Service is buying office supplies directly from small, minority-, and woman-owned businesses.
The Postal Service has not been successful in implementing its national-level contract to purchase most office supplies from Boise. Although the national contract was intended to be a mandatory source of office supplies, the Postal Service purchased less than 40 percent of its office supplies from Boise in 2001. GAO found that the Postal Service did not perform as planned under the contract because it did not take sufficient actions to ensure that the contract would be used. As a result, the Postal Service has not been able to realize its estimated annual savings of $28 million. In fact, it was only able to provide documentation for $1 million in savings for 2001. Boise and the Postal Service have not paid sufficient attention to the subcontracting plan. The plan contains obvious ambiguities, and, in fact, Postal Service and Boise officials disagree on its goals. The Postal Service maintains that the goal is 30 percent of Boise's annual revenue from the contract. Boise has fallen far short of this goal, reporting that only 2.6 percent of subcontracting dollars were awarded to small, minority-, and woman-owned businesses in fiscal year 2001. Postal Service and Boise officials recognize that the performance on the subcontracting plan is not satisfactory and are taking a number of steps to achieve the plan's goals. Nevertheless, it is highly unlikely that the current subcontracting goals will be met. The Postal Service reported that its small, minority-, and woman-owned business achievements have declined from fiscal years 1999 to 2001. Despite the Postal Service's reported statistics, we could not determine the extent to which it is buying directly from these businesses because the data are unreliable.
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Report to the Chairman and Ranking Member, Committee on Small Business,
House of Representatives:
United States General Accounting Office:
GAO:
January 2003:
Contract Management:
Postal Service‘s National Office Supply Contract Has Not Been
Effectively Implemented:
GAO-03-230:
GAO Highlights:
Highlights of GAO-03-230, a report to the Chairman and Ranking Member,
Committee on Small Business, House of Representatives:
Why GAO Did This Study:
Over the past 2 years, the Postal Service has experienced growing
financial difficulties. In an effort to transform the organization to
reduce costs and increase productivity, the Postal Service awarded a
national-level office supply contract to Boise Corporation. In
addition, the Postal Service required Boise to submit a subcontracting
plan, which outlines how small, minority-, and woman-owned businesses
will be reached through the contract. GAO was asked to assess the
status of the Postal Service‘s implementation of the Boise contract
and Boise‘s achievement of its subcontracting plan. GAO also reviewed
the extent to which the Postal Service is buying office supplies
directly from small, minority-, and woman?owned businesses.
What GAO Found:
The Postal Service has not been successful in implementing its
national-level contract to purchase most office supplies from Boise.
Although the national contract was intended to be a mandatory source
of office supplies, the Postal Service purchased less than 40 percent
of its office supplies from Boise in 2001. GAO found that the Postal
Service did not perform as planned under the contract because it did
not take sufficient actions to ensure that the contract would be used.
As a result, the Postal Service has not been able to realize its
estimated annual savings of $28 million. In fact, it was only able to
provide documentation for $1 million in savings for 2001.
Boise and the Postal Service have not paid sufficient attention to the
subcontracting plan. The plan contains obvious ambiguities, and, in
fact, Postal Service and Boise officials disagree on its goals. The
Postal Service maintains that the goal is 30 percent of Boise‘s annual
revenue from the contract. Boise has fallen far short of this goal,
reporting that only 2.6 percent of subcontracting dollars were awarded
to small, minority-, and woman-owned businesses in fiscal year 2001.
Postal Service and Boise officials recognize that the performance on
the subcontracting plan is not satisfactory and are taking a number of
steps to achieve the plan‘s goals. Nevertheless, it is highly unlikely
that the current subcontracting goals will be met.
The Postal Service reported that its small, minority-, and woman-owned
business achievements have declined from fiscal years 1999 to 2001.
Despite the Postal Service‘s reported statistics, we could not
determine the extent to which it is buying directly from these
businesses because the data are unreliable.
Highlights Figure:
[See PDF for image]
[End of figure]
What GAO Recommends:
GAO is recommending that the Postal Service reexamine the national
office supply contract to determine why it is not being used and
whether
it is an effective tool to achieve savings. If the contract is found to
be beneficial, the Postal Service should track its employees‘ use of
the
contract. GAO also recommends the Postal Service revise its national
contract to reflect realistic goals for small, minority-, and
woman-owned businesses. The Postal Service agreed with GAO‘s
recommendations.
Contents:
Letter:
Results in Brief:
Background:
National-Level Office Supply Contract Has Not Been Fully Implemented:
Boise Is Not Achieving Subcontracting Plan Goals:
Reports Indicate a Drop in Small Business Dollars, but Data Are
Unreliable:
Conclusions:
Recommendations:
Agency Comments:
Scope and Methodology:
Appendix I: Comments from the U.S. Postal Service:
Appendix II: Comments from Boise Office Solutions:
Tables:
Table 1: Boise‘s Reported Fiscal Year 2001 Subcontracting Achievements:
Table 2: Reported Office Supplies Purchased from SMW Businesses:
Table 3: Reported Office Supplies Purchased through Contracts:
Table 4: Reported Office Supplies Purchased Using Purchase Card:
Figures:
Figure 1: Total Office Supply Spending for Fiscal Year 2001:
Figure 2: Office Supply Spending (Fiscal Years 1999 to 2001):
Figure 3: Postal Service Office Supply Spending with Contract Vendors
(Fiscal Years 1999 to 2001):
Abbreviations:
JWOD: Javits-Wagner-O‘Day Act:
SMW: small, minority-owned, and woman-owned:
January 17, 2003:
The Honorable Donald A. Manzullo
Chairman
The Honorable Nydia M. Velázquez
Ranking Democratic Member
Committee on Small Business
House of Representatives:
Over the past two years, the United States Postal Service experienced
growing financial difficulties and struggled to fulfill its mission of
providing affordable, high-quality universal service, while remaining
self-supporting. Consequently, GAO reported that the Postal Service‘s
current business model was at risk and placed its transformation and
long-term outlook on our high-risk list in April 2001.[Footnote 1] To
transform the organization, reduce costs, and increase productivity,
the Postal Service is, among other things, redesigning purchasing and
material management functions to capture potential savings through a
supply chain management initiative. The supply chain encompasses
marketing, distribution, planning, manufacturing, and purchasing. One
area of focus for this initiative is office supplies, on which the
Postal Service spent $125 million in fiscal year 2001.[Footnote 2] To
implement supply chain management for office supplies, the Postal
Service awarded a national office supply contract to Boise Office
Solutions (Boise) in January 2000.[Footnote 3] Under the terms of the
contract, Postal Service buyers are required, with a few exceptions, to
purchase all office supplies from this contract. The Postal Service
estimated that this contract would enable it to save up to
$28 million annually.
The Postal Service, which is not subject to the Small Business
Act,[Footnote 4] is not required to establish goals for contract awards
to small businesses. However, the Postal Service has established a
supplier diversity program and tracks dollars awarded to small,
minority-owned, and woman-owned (SMW) businesses (minority-and woman-
owned businesses can be large or small). One of the ways the Postal
Service expects to increase the dollars going to these businesses is
through SMW subcontracting. For example, Boise was required to submit a
subcontracting plan to reach SMW businesses. In light of the potential
impact of the Boise contract on small business vendors, you asked us to
assess (1) the status of the Postal Service‘s implementation of its
national contract with Boise, (2) Boise‘s achievement of its SMW
subcontracting plan goals, and (3) the extent to which the Postal
Service is buying office supplies directly from SMW businesses.
Results in Brief:
The Postal Service has not yet been successful in implementing its
national office supply contract. Although the contract was intended,
with a few exceptions, to be a mandatory source of supply, in fiscal
year 2001 the Postal Service spent over 60 percent of its office supply
dollars on items purchased outside the Boise contract through purchase
cards, other contracts, money orders, or cash. The lack of success was
due in part to insufficient actions taken by the Postal Service to
ensure that office supplies are purchased from the Boise contract. The
Postal Service was unaware of the extent to which the contract was not
being used because it has not adequately tracked or monitored its
employees‘ office supply purchases. For fiscal year 2001, the Postal
Service can document only $1 million in savings from the use of the
contract--though it had projected savings of up to $28 million.
Boise and the Postal Service have not paid sufficient attention to
subcontracting goals. The subcontracting plan was carelessly
constructed and contains ambiguities that should have been resolved
prior to the contract award. However, to date, Boise and the Postal
Service have not taken actions to revise the plan. For example, the
categories of SMW businesses in the plan are inconsistent with the way
Boise has been reporting its achievements and with the way the Postal
Service categorizes its diversity goals. Moreover, Boise and Postal
Service officials do not agree on the goals. According to Postal
Service officials, the overall goal is 30 percent of annual revenue for
the contract--a figure confirmed in a preaward email from Boise.
According to a Boise official, the goal is both a percentage of annual
revenue for the contract as well as a fixed dollar value. Boise has
fallen far short of the 30 percent goal. In fiscal year 2001, Boise
reported that only 2.6 percent of its revenue was subcontracted to SMW
businesses. Both Boise and the Postal Service now acknowledge that the
30 percent goal may have been unreasonable. Recently, Boise has begun
to take actions to improve its performance. Nevertheless, it is highly
unlikely that Boise will achieve its subcontracting goal.
The extent to which the Postal Service is buying office supplies
directly from SMW vendors is unclear. From fiscal years 1999 through
2001, Postal Service data show that office supply purchases from SMW
businesses through contracts and purchase cards decreased from
50 percent to 18 percent. However, the data are unreliable. The Postal
Service has not tracked SMW business participation in other purchasing
mechanisms, such as money orders and cash, and, like other agencies,
its information on purchase card merchants contains numerous errors.
We are making recommendations to the Postmaster General of the
United States concerning the need to re-assess the Postal Service‘s
national office supply strategy and estimated savings and to revise
Boise‘s subcontracting plan to accurately and clearly reflect realistic
goals. In written comments on a draft of this report, the Postal
Service agreed with our recommendations. Boise also provided written
comments, offering its perspective on some of the information in
the report.
Background:
The Postal Service, an independent establishment of the executive
branch of the U.S. government,[Footnote 5] is the largest federal
civilian agency, consisting of more than 38,000 post offices, branches,
and stations and 350 major mail-processing and distribution facilities.
As part of its strategy for better managing its procurement of goods
and services, the Postal Service has centralized the procurement of
commodities that were previously decentralized. For example, all office
supply procurements are now managed by the Office Products and
Utilities Category Management Center in Windsor, Connecticut, which is
responsible for administering the national contract. Previously,
office supply procurement was decentralized, with each area managing
its own procurements.
To demonstrate its commitment to reaching SMW businesses, the
Postal Service has developed a 5-year supplier diversity plan. The
plan focuses on maintaining a strong supplier base that includes
SMW businesses. While it does not set specific dollar goals, the plan
is intended to ensure that the Postal Service spends an increasing
amount of its procurement dollars on goods and services from diverse
businesses through fiscal year 2003. To monitor its progress, the
Postal Service measures its prime and subcontracting spending
achievements with SMW businesses.
During fiscal years 1999 through 2001, Postal Service procurement of
goods and services (which includes office supplies) decreased from
$3.5 billion to $2.6 billion. For the same time period, office supply
procurement grew from $107 million to $125 million. Postal Service
officials explained that this increase does not necessarily indicate
an actual increase in office supply spending, but rather it reflects
improvements in the procurement system‘s ability to track spending.
The officials indicated that the data provided, while not perfect, are
the best available information.
In October 1999, the Postal Service issued a solicitation for a
national-level office supply contract. Four vendors submitted
proposals. The solicitation provided that the award would be made to
the vendor that offered the best overall value to the government,
considering nonprice and price factors. The proposals were evaluated
based on several factors, including the vendors‘ demonstrated
understanding of the solicitation‘s (1) technical requirements,
including the ability to implement and maintain a Web-based procurement
system, and (2) business requirements. As part of their business plan,
vendors were required to demonstrate their ability to deliver items
within 24 hours of receiving an order, which is considered industry
standard. Other factors on which the proposals were evaluated,
in descending order of importance, were:
* the inclusion of a subcontracting plan demonstrating the vendor‘s
commitment to use SMW businesses,
* the ability to address environmental and energy conservation efforts.
* An explanation of the price discounts on items offered to the
Postal Service,
* the ability to provide financial and purchasing reports that are
integrated with the Postal Service‘s system, and:
* the ability to provide Postal Service items, other than office
supplies, that are used in an office setting.
Additional evaluation factors included past performance and
Javits-Wagner-O‘Day Act (JWOD)[Footnote 6] compliance.
The Postal Service awarded the contract to Boise with a start date
of April 3, 2000. The contract is a firm, fixed-price modified
requirements contract for a 3-year base period, with up to three 2-year
options. The contract requires, with a few exceptions, that the Postal
Service order from Boise all of the approximately 13,000 items in
Boise‘s Postal Service office supply catalog. Exceptions to the
mandatory requirement are where (1) the item can be found at a lower
price (and it is not a JWOD item) or (2) the requirement is urgent and
the supplier cannot meet the required delivery date. The Postal Service
has since exercised the first 2-year option.[Footnote 7]
The JWOD Act requires the Postal Service to comply with its
requirements.[Footnote 8] According to Postal Service and Boise
officials, Boise has ensured through its ordering process that this
compliance occurs. When Postal Service employees place an order with
Boise for an item that is also on the JWOD procurement list, Boise
substitutes the ordered item with a JWOD item that is essentially the
same.
National-Level Office Supply Contract Has Not Been Fully Implemented:
The Postal Service has not been successful in implementing its
national-level contract to purchase most office supplies from Boise.
As shown in figure 1, during fiscal year 2001 less than 40 percent of
the $125 million in office supplies was purchased from the contract.
Figure 1: Total Office Supply Spending for Fiscal Year 2001:
[See PDF for image]
[End of figure]
Note: ’Other“ is local buys paid by cash, money orders, and district
invoices.
The Postal Service has not taken sufficient actions to ensure that the
contract would be used as anticipated. While fiscal year 2001 data show
an improvement over the 6 months that the contract was used in fiscal
year 2000, when about 75 percent of office supplies were purchased
outside the contract, the Postal Service is concerned that its
employees continue to spend a significant percentage of office supply
dollars outside the contract. Anticipated savings were based on the
assumption that almost all supplies would be purchased from the
national contract. The fact that this has not occurred, together with
the absence of a benchmark against which to measure savings, has
contributed to the Postal Service‘s failure to realize estimated
savings from its supply chain initiative.
Postal Service Did Not Take Sufficient Actions to Ensure Contract
Would Be Used:
Although the Postal Service conducted market research that supported
the implementation of a national-level contract for office supplies, it
did not take sufficient actions to ensure that the contract would be
used as anticipated. Figure 2 shows that Postal Service employees buy
office supplies through three mechanisms: contracts (including Boise
and non-Boise contracts), purchase cards, and other methods such as
cash and money orders.
Figure 2: Office Supply Spending (Fiscal Years 1999 to 2001):
[See PDF for image]
[End of figure]
Postal Service officials stated that the increase in contract dollars
from fiscal year 1999 to 2001 indicates that the national contract is
being used more extensively. However, they have not determined why
employees continue to buy their supplies outside the contract. Postal
Service officials did not expect immediate compliance with the
contract; they anticipated that some purchasing would occur outside the
national contract during the implementation period because the cultural
environment of the Postal Service has allowed local buyers to make
purchases independently. However, they were unaware of the extent to
which the contract is not being used because they did not sufficiently
plan its implementation, nor have they adequately tracked and monitored
office supply purchases.
There are several indications that the Postal Service did not take
sufficient action to ensure that the contract was properly implemented.
First, the Postal Service continues to maintain a number of non-Boise
office supply contracts. Although the number of vendors on these other
contracts declined from 49 to 33 from fiscal years 1999 through 2001,
the dollar value of supplies bought from these contracts has grown, as
shown in figure 3.
Figure 3: Postal Service Office Supply Spending with Contract Vendors
(Fiscal Years 1999 to 2001):
[See PDF for image]
[End of figure]
Note: Boise spending in fiscal year 1999 represents business from its
existing contract with the Postal Service, prior to the national
contract award.
The Postal Service did not undertake a systematic review of all office
supply contracts when it implemented the national contract. Such an
assessment would have provided an indication of which non-Boise
contracts should have been continued and which phased out. In fact,
some of the items purchased under non-Boise contracts in fiscal year
2001--such as binders, paper, and measuring tape--should have been
purchased from Boise, according to the terms of the national contract.
According to Postal Service officials, other items--such as printed
envelopes and some types of rubber bands--are purchased under separate
contracts because the items are not part of the Boise catalog or they
are unique and purchased in volume. Postal Service officials told us
that the improved oversight they expect as a result of centralized
office supply procurement will allow them to phase out some of the
existing office supply contracts.
Second, Postal Service employees continue to use purchase cards to buy
office supplies outside the contract. Because the purchase card cannot
be used to order from the Boise contract, none of the $16.8 million
spent on office supplies through purchase cards in fiscal year 2001 was
spent under the contract. Postal Service officials have not tracked or
monitored purchase card procurements to determine why these employees
are not using the contract. Postal Service managers indicated that they
are able to use quarterly purchase card spending reports to identify
errant purchases--office supplies that should have been purchased from
the national contract. However, they acknowledge that these reports are
not used consistently to monitor employee purchases of office supplies.
Finally, Postal Service employees continue to use cash and money orders
to buy supplies from local vendors. As with the purchase cards, cash
and money orders cannot be used to buy supplies from the Boise
contract. Because the Postal Service has limited information about cash
and money order purchases, it was unaware that 33 percent of office
supply spending in fiscal year 2001 occurred through these methods.
Postal Service officials remarked that they are encouraged by the
decrease (from about $66 million in fiscal year 1999 to $41 million in
fiscal year 2001) in office supply purchasing using cash and money
orders. However, until the Postal Service is able to better track and
monitor local office spending, it will lack the information it needs to
ensure that the national contract is being used as intended.
Postal Service officials explained that their ability to track office
supply spending--enabling them to better target those employees who are
not using the contract--should improve as Boise contract use increases
because the contract requires Postal Service employees to use a
Web-based purchasing system referred to as e-buy.[Footnote 9] The
Postal Service‘s expectation is that information about e-buy purchases
will be systematically and consistently collected. However, use of the
contract is not being enforced, and employees continue to use other
methods--such as contracts outside the national contract, purchase
cards, cash, and money orders--to buy office supplies.
Postal Service is Unable to Document Estimated Savings:
The Postal Service‘s decision to award a national-level contract to a
single supplier was based, in part, on an expectation of saving up to
$28 million annually. These savings would result from (1) purchasing a
large quantity of items from a single supplier, thereby reducing item
costs, and (2) implementing the e-buy purchasing process, which would
reduce overall transaction costs. To realize the maximum benefits and
cost savings under the Postal Service‘s acquisition strategy, almost
all office supplies must be purchased from Boise. However, the fact
that employees continue to buy supplies outside the contract, combined
with the lack of an established benchmark to measure savings, prevents
the Postal Service from determining whether it is achieving its savings
goals.
The Postal Service‘s reported savings are calculated using a formula
established in 1999. The formula is based on market research, Postal
Service Annual Report data from 1998, and spending on an office supply
contract in existence at that time. This methodology predicted
transaction cost savings of up to 70 percent and item price savings of
up to 10 percent on a $50 million contract. The Postal Service claimed
savings of up to $28 million for fiscal year 2001 using these
estimates. However, when we asked for evidence of actual savings to
date, the Postal Service could provide documentation for only about
$1 million. This amount reflects rebates that Boise agreed to give the
Postal Service on all new business and reduced prices negotiated as
part of the contract.
Boise Is Not Achieving Subcontracting Plan Goals:
Boise and the Postal Service have not paid sufficient attention to the
subcontracting goals under the national office supply contract. The
subcontracting plan was carelessly constructed, and it contains obvious
ambiguities. In fact, Postal Service and Boise officials do not agree
on the basic subcontracting goals. Notwithstanding this disagreement,
for the purposes of this report we have used the Postal Service‘s
position that the goal is to award 30 percent of annual revenues to SMW
businesses.
Boise has fallen far short of achieving the 30 percent goal. In fiscal
year 2001, Boise reported achievements of only 2.6 percent. Boise has
also fallen short of its specific goals for minority and woman-owned
businesses. Boise and the Postal Service provided several reasons why
Boise is not achieving the subcontracting goals and they have
identified actions that they believe will improve performance. However,
these actions will not be sufficient to enable Boise to reach its
subcontracting plan goals.
When Boise initially submitted its proposal, its subcontracting goal
was to provide 12 percent of its Postal Service business to SMW
subcontractors. This proposed subcontracting plan included 4 percent
goals for minority-and woman-owned businesses. However, after Boise was
selected as the intended awardee--but before the contract was awarded-
-the goal for SMW businesses was increased to 30 percent based on
negotiations with the Postal Service. At the same time, Boise increased
its goals for minority-and woman-owned business from 4 to 6 percent.
Subcontracting Plan Contains Inconsistencies:
The subcontracting plan contains obvious ambiguities that should have
been addressed prior to contract award. For example, because the plan
is not clearly written, Postal Service and Boise officials disagree on
the overall SMW subcontracting goal. Postal Service officials maintain
that the goal is 30 percent of overall revenue for the contract, a
figure confirmed in a preaward email from Boise. A Boise official,
however, asserts that there is both an overall 30 percent goal and a
fixed dollar value goal of $3,300,000. Despite this disagreement,
neither Boise nor Postal Service officials have taken steps to revise
the plan.
Further, the subcontracting plan misstates two of the three reporting
categories for which there is a contractual goal. The language in the
plan includes goals for ’small, disadvantaged businesses“ and ’small,
woman-owned businesses.“ In practice, however, the Postal Service and
Boise report achievements for ’minority“ and ’woman-owned“ firms, which
may be small or large. There is no clear linkage between the categories
of SMW businesses as stated in the plan and the way Boise is reporting
its achievements. A Boise official explained that the subcontracting
plan reflects the categories the firm typically uses when contracting
with federal agencies, and it did not revise the reporting categories
to reflect the Postal Service‘s supplier diversity categories. In
responding to our questions, the Postal Service officials acknowledged
that the plan is inconsistent with the way Boise‘s achievements are
measured and that it needs to be revised.
Boise‘s Reported Achievements:
Despite its disagreement with the Postal Service about the
subcontracting goals, Boise reports the dollars and percentages that
went to SMW businesses based on the annual total revenues under the
contract. Table 1 reflects reported achievements for fiscal year 2001.
Table 1: Boise‘s Reported Fiscal Year 2001 Subcontracting Achievements:
Reported achievements; Percent of dollars to SMW businesses: 2.6%;
Total dollars to SMW businesses: $1,245,161; Percent of dollars to
minority businesses: 0.7%; Total dollars to minority businesses:
$345,556; Percent of dollars to woman-owned businesses: 1.9%; Total
dollars to woman-owned businesses: $899,625.
Source: Boise.
Note: Boise‘s total sales to the Postal Service on the national
contract for fiscal year 2001 were $47 million.
[End of table]
Postal Service and Boise officials stated that 30 percent was a stretch
goal to demonstrate the Postal Service‘s commitment to supplier
diversity. A Boise representative stated that Boise agreed to the
30 percent goal because Boise understood the goal to be negotiable.
Even though the Postal Service has no plans to renegotiate the goal
before the end of the initial contract performance period of 3 years,
Boise and the Postal Service have started discussions to renegotiate
the subcontracting goal in the event that the Postal Service decides to
exercise an option to extend the contract. Postal Service officials
noted that they realize, in hindsight, that the 30 percent goal may
have been unreasonable.
Several Reasons Offered for Failure to Meet the Goals:
Boise and Postal Service officials provided several reasons why the
subcontracting goals have not been achieved. First, a Boise official
said that Boise agreed to the 30 percent goal based on its earlier
achievements under the General Services Administration‘s Federal Supply
Schedules program.[Footnote 10] In fiscal years 1999 and 2000, Boise
awarded small businesses 24.6 percent of its Schedules program sales.
In retrospect, Boise and Postal Service officials explained that the
Schedules program was not a reliable source for an estimate because
Boise‘s contract under the Schedules program included 1,800 items,
compared to about 13,000 items in the Postal Service contract.
Moreover, the total dollar sales in Boise‘s Schedules contract--
$14.3 million in fiscal year 2000--were considerably lower than the
total sales on the Postal Service contract--$47 million in fiscal
year 2001.
Second, while Boise has a corporate supplier diversity strategy, a
Boise official stated that the company‘s ability to achieve the
subcontracting plan goals has been hampered by the fact that the Postal
Service does not require its employees to target SMW businesses when
ordering from the catalog. In fact, officials at one district we
visited had the impression that by simply purchasing from the contract
they were complying with the Postal Service‘s SMW business initiatives.
At another district we visited, employees were not aware that the
Postal Service had SMW subcontracting goals in the contract. All of the
district officials we spoke with stated that they base their purchasing
decisions on the lowest available price and do not search the catalog
for SMW businesses.
Third, one of the primary reasons Boise and Postal Service officials
offered for the low subcontracting achievements was that compliance
with the JWOD Act is taking away dollars from small businesses.
However, Boise records show that of the 47 Boise vendors whose items
were replaced with JWOD items in fiscal year 2001, only 7 were small
businesses. These 7 vendors supply 26 out of the 404 Postal Service
office supply items that are subject to the automatic JWOD replacement.
Moreover, financial data from Boise show that in calendar year 2000,
while total sales on JWOD items were just over $3 million, the impact
of JWOD compliance on these 7 vendors was relatively small. These
vendors potentially lost $167,629 in business due to the automatic
substitution of JWOD items for their items. In calendar year 2001
(representing one full year of contract sales), these 7 vendors
potentially lost $297,036 of sales, while the total sales on JWOD items
for the year doubled to almost $6 million. This trend continued in the
first 6 months of 2002.
Finally, Postal Service officials also explained that Boise could not
reach its goal because it had planned to subcontract with a woman-owned
enterprise that provided cash register tapes, a technology that the
Postal Service decided to phase out. They stated that although Boise
had relied on this business to reach its subcontracting goal, a change
in technology resulted in significantly less business with this vendor
than was expected. However, neither Postal Service nor Boise officials
could provide us with specific estimates of expected sales. In fact,
sales to this woman-owned firm increased in 2001 and 2002. Boise
records show a growth in sales of the cash register tapes from this
business of approximately $283,000 in 2000 to $455,000 in 2001. Sales
for the first half of 2002 indicate a dollar amount in sales similar to
the total sales in 2001. Moreover, Boise was notified of the changes to
the new technology as far back as 1998; therefore, this was not new
information received during the negotiations regarding the
subcontracting goals.
Actions to Improve Subcontracting Performance:
The Postal Service and Boise recognize that the performance on the
subcontracting plan is not satisfactory and have started to take some
actions to improve Boise‘s achievements under the current contract.
While Boise is responsible for its contract performance, the
coordinated actions of the Postal Service and Boise can assist Boise‘s
ability to achieve the subcontracting plan goals. Although the
following steps are being taken to improve performance, it is highly
unlikely that these actions will enable Boise to reach its 30 percent
subcontracting goal.
* Boise is working with the Postal Service to include additional SMW
businesses as subcontractors. For example, Boise continues to work with
the Postal Service to identify small business suppliers of recycled
toner cartridges, who in many cases provide their products at half the
price of new toner cartridges. District officials received a listing of
small businesses supplying recycled toner cartridges in October 2001.
However, neither the Postal Service nor Boise has determined the extent
to which this information will increase Boise‘s subcontracting
achievements.
* Boise is working with the Postal Service to reflect indirect services
provided to Boise by small businesses in its reporting of
subcontracting plan achievements, as it is allowed to do under the
Postal Service contract. Indirect services include data entry and
information management services, such as invoicing and tracking sales
information. However, Boise estimates that including indirect services
provided by SMW businesses will have minimal impact on subcontracting
plan achievements. Currently, there is no time frame for implementing
this change in Boise‘s reporting of its subcontracting achievements.
* In October 2001, the Postal Service and Boise teamed up to design a
quarterly report that tracks SMW business purchases at the Postal
Service districts. The Postal Service expects to finalize and
distribute these reports in January 2003.
* The Postal Service and Boise are expanding the education of Postal
Service employees on the benefits of seeking out SMW suppliers when
they order office supplies from the national contract. Since initial
office supply contract training was provided in the fall of 2000,
Postal Service efforts to educate employees about SMW suppliers have
been through informal channels, such as e-mail. Boise‘s educational
efforts focus on providing more information to the Boise sales
representatives that work with the Postal Service. While Boise expects
some improvements in its subcontracting achievements as a result of the
educational efforts, their impact is unknown.
Reports Indicate a Drop in Small Business Dollars, but Data Are
Unreliable:
Postal Service data show that office supply purchases made directly
from SMW businesses--using contracts and purchase cards--decreased from
about 50 to 18 percent from fiscal year 1999 through 2001. However, the
extent to which the Postal Service is buying office supplies from SMW
businesses is unclear because its purchase card information is
unreliable and because the Postal Service has not tracked purchases by
employees using mechanisms such as money orders and cash. Our review,
as well as a report by the Postal Service Inspector General,[Footnote
11] found that incomplete and unreliable diversity statistics on
suppliers resulted in the Postal Service overstating or incorrectly
classifying dollars awarded to SMW businesses. The Inspector General‘s
report made nine recommendations to correct the reporting of diversity
statistics.[Footnote 12]
Table 2 shows the decline in the percentage of SMW purchases from
fiscal years 1999 through 2001, based on Postal Service data.
Table 2: Reported Office Supplies Purchased from SMW Businesses:
Office supplies: Total purchases; 1999: $ 107,181,787; 2000: $
107,392,563; 2001: $ 125,047,235.
Office supplies: SMW purchases; 1999: $ 20,207,461; 2000: $ 16,939,654;
2001: $ 15,002,143.
Office supplies: SMW purchases as percent of total purchases; 1999:
19%; 2000: 16%; 2001: 12%.
Office supplies: Total purchases using contracts and purchase cards
only; 1999: $41,211,956; 2000: $49,714,964; 2001: $83,748,545.
Office supplies: SMW as percent of total purchases using contracts and
purchase cards; 1999: 49%; 2000: 34%; 2001: 18%.
Source: GAO analysis of U.S. Postal Service data.
Note: ’Total purchases“ reflects contracts, purchase cards and other
purchasing mechanisms such as money orders and cash.
[End of table]
During the same 3-year period, SMW business participation has decreased
as a percentage of contract spending (excluding spending through
purchase cards, cash, and money orders), while the overall dollar value
of office supplies purchased through contracts increased from
$14.5 million to almost $67 million. In addition, the number of SMW
vendors selling office supplies to the Postal Service decreased during
this period. Postal Service district officials told us that they are no
longer attempting outreach to local SMW businesses--such as
participating in small business conferences or trade shows to attract
new vendors--because of the emphasis on buying office supplies only
through the Boise contract. Table 3 shows the decline in contract
activity with small businesses from fiscal years 1999 through 2001.
Table 3: Reported Office Supplies Purchased through Contracts:
Purchase of office supplies using contracts; 1999: $ 14,500,475; 2000:
$ 25,148,837; 2001: $ 66,930,690.
Contract purchases from SMW businesses; 1999: $ 5,440,943; 2000: $
9,150,457; 2001: $ 9,938,844.
SMW businesses as percent of total contract spending; 1999: 38%; 2000:
36%; 2001: 15%.
SMW vendors; 1999: 27; 2000: 29; 2001: 17.
Source: GAO analysis of U.S. Postal Service data.
[End of table]
Similarly, the Postal Service reports that office supply procurements
from SMW businesses through purchase cards decreased from fiscal years
1999 through 2001. Table 4 shows the decline in the percentage of
purchases from SMW businesses using purchase cards from fiscal year
1999 through 2001.
Table 4: Reported Office Supplies Purchased Using Purchase Card:
Total purchase card spending; 1999: $26,711,481; 2000: $24,566,126;
2001: $16,817,855.
Purchase card purchases from SMW businesses; 1999: $14,766,518; 2000:
$7,789,198; 2001: $5,063,299.
SMW businesses as percent of total purchase card spending; 1999: 55%;
2000: 32%; 2001: 30%.
Source: GAO analysis of U.S. Postal Service data.
[End of table]
Despite the Postal Service‘s reported statistics, we could not
determine the extent to which the Postal Service is buying from SMW
businesses. First, because the Postal Service does not track or report
socioeconomic data when payments are made to vendors using cash or
money orders, it is not possible to assess SMW business achievements
when those payment methods are used.
Second, the Postal Service, like other federal agencies, relies on
reports from banks for annual purchase card transaction and vendor
information. This information is ambiguous and contains numerous errors
because socioeconomic categories are often inaccurate. For example, the
Postal Service‘s purchase card data for fiscal years 1999 through 2001
included over $40 million dollars in office supply purchases from
businesses that were identified as both small and large.
The Postal Service is aware of the problems with the purchase card
transaction information and has been working with Visa Corporation to
improve the data. Because banks and payment card associations, such as
Visa, control the transaction databases, the Postal Service must rely
on the information provided by these institutions. We recently reported
on the issue of unreliable and incomplete socioeconomic data on
purchase card merchants.[Footnote 13]
Conclusions:
The Postal Service has not achieved its goal of using a single supplier
for office supplies and, as a result, has not achieved its anticipated
savings. Because the Postal Service has not analyzed how its employees
buy office supplies, it does not know why the national contract is not
being used as extensively as planned. In fact, the Postal Service has
no assurance that the national strategy is effective because it has not
adequately tracked its employees‘ office supply purchases.
Implementing a national-level office supply contract through a single
supplier makes the realistic development and measurement of Boise‘s
subcontracting goals and achievements critical to the Postal Service‘s
efforts to achieve its supplier diversity objectives. The failure to
establish an effective subcontracting plan and the lack of oversight
and enforcement has created an environment where participation by SMW
businesses is minimal. The fact that the Postal Service and Boise
cannot agree on the levels of SMW participation established in the
contract is evidence of the lack of attention Boise and the Postal
Service have paid to this issue. While Boise and the Postal Service
have taken some actions to address SMW achievement, it is highly
unlikely that Boise will be able to reach its subcontracting goal.
Recommendations:
We recommend that the Postmaster General of the United States:
* determine why the national contract is not being used as a mandatory
source of office supplies;
* reassess the cost effectiveness of a national office supply contract
and measure actual savings from using the contract rather than applying
the outdated estimating formulas initially established;
* develop mechanisms to track employees‘ compliance with the mandatory
use of the contract, if analysis indicates that the national-level
contract is beneficial; and:
* direct that the contract be modified to include a revised
subcontracting plan that accurately and clearly reflects realistic
goals for small, minority, and woman-owned businesses, consistent with
the Postal Service‘s supplier diversity program.
Agency Comments:
In written comments on a draft of this report, the Postal Service
agreed with our recommendations and indicated that our report will help
it develop and enforce policies aimed at improving performance under
the national office supply contract. Recognizing that the success of a
contract such as this requires continuous management, the Postal
Service has established a new supply management organization that will
use our findings and recommendations to determine why the contract is
not being used as fully as anticipated. The Postal Service indicated
that it will continue to seek cost-effective ways to expand its
oversight efforts and expects that increased use of the Web-based
purchasing system will assist in these efforts. Regarding the savings
from the contract, the Postal Service stated that its internal analysis
has validated $5.3 million in cost reductions during fiscal year 2002.
This analysis was not shared with us during our review. Finally, the
Postal Service stated that it has corrected the ambiguities in the
subcontracting plan and is working with Boise to establish more
realistic subcontracting goals. The Postal Service‘s letter appears in
appendix I.
We also received a written statement from Boise expressing its opinion
on federal subcontracting involving SMW businesses and offering several
comments on our findings. Boise stated that actual sales under the
contract (approximately $50 million) far exceeded its expected contract
amount of $11 million. Boise uses this information as a rationale for
its failure to achieve its subcontracting goals, which it asserts were
based on the $11 million expected contract amount. However, the
contract did not guarantee a minimum or maximum level of sales to Boise
and, as noted in our report, a 30 percent goal was confirmed by Boise
in a pre-award e-mail. Further, the Postal Service based its projected
savings on an estimated contract amount of $50 million. Boise also
noted that sales to SMW businesses with the Postal Service increased
from fiscal year 1999 to fiscal year 2001. However, Boise‘s analysis
relies on a comparison of sales data from a previously existing Postal
Service office supply contract, for 200 high-use items, to the sales
data from the current contract, which covers almost 13,000 items.
Because Boise is comparing sales data from two different contracts, we
do not believe that this is a legitimate comparison. Boise indicated
that it is working with the Postal Service to correct the
inconsistencies we noted in the subcontracting plan.
In addition, Boise believes that JWOD items block sales to SMW
businesses; however, Boise did not provide sufficient evidence to
support this claim. As noted in our report, the potential lost sales to
SMW businesses due to JWOD item replacements were relatively small.
Boise also commented that because sales of a cash register tape made by
a woman-owned business did not increase at the expected rate, its SMW
achievements were affected. However, as discussed in our report,
neither Boise nor the Postal Service could provide us with
documentation on the expected sales of the IRT tapes.
Finally, Boise was concerned about our selection of field sites because
it was not based on a random sample. We targeted locations that,
according to Boise‘s data, were low users of the contract. The
objective of our field visits was not to identify overall awareness of
the contract. Rather, our intent was to gain an understanding of why
certain locations were not using the contract as a mandatory source of
office supplies. Boise‘s letter appears in appendix II.
Scope and Methodology:
To meet our objectives, we reviewed the Postal Service‘s office supply
spending and the related SMW achievements during fiscal years 1999
through 2001.
To examine the status of the Postal Service‘s implementation of its
national office supply contract with Boise, we reviewed the acquisition
planning, contract formation, and contract administration
documentation, including market research results, the solicitation, and
the contract. Total office supply spending was identified using
information from the Postal Service purchasing and materials data
warehouse. We determined office supply spending for fiscal years 1999
through 2001 by using the same account codes that the Postal Service
used to conduct its market research to justify the national office
supply contract. We reviewed the Postal Service‘s total office supply
spending details for all contract, purchase card, money order, and cash
transactions. We did not independently verify the accuracy of the
reported spending. We interviewed and obtained information from the
Postal Service‘s contracting officer and contract administrator. In
addition, we interviewed and obtained information from three area
offices and three district offices based on data that indicated these
locations were not using the national office supply contract. We
interviewed purchasing specialists, administrative services managers,
financial system coordinators, and administrative personnel with office
supply purchasing responsibility. We also held discussions with and
acquired information from Boise‘s federal business manager.
To determine Boise‘s achievement of its SMW subcontracting plan, we
reviewed the contract‘s subcontracting plan and Boise‘s quarterly
reports on its SMW achievements. We interviewed and obtained
information from the Postal Service‘s contracting officer, area finance
officials, and district finance and purchasing officials. We also held
discussions with and acquired information from Boise‘s federal business
manager, its minority-and woman-owned business development and supplier
diversity manager, and two minority-owned subcontractors.
To assess the extent to which the Postal Service is buying office
supplies directly from SMW businesses, we reviewed Postal Service
supplier diversity policy and guidance. We examined the Postal
Service‘s reported socioeconomic statistics, including the dollar
amount and type of vendor for fiscal years 1999 through 2001. We
interviewed and obtained information from Postal Service officials in
the offices of supplier development and diversity, purchasing and
materials, and the Postal Service Inspector General. We determined that
the reported purchase card data were unreliable; however, we did not
attempt to correct the errors in the data provided.
Additionally, we met with representatives from the National Office
Products Association and a small, woman-owned business to gain a better
understanding of their views with regard to the national contract.
We conducted our review from March 2002 to November 2002 in accordance
with generally accepted government auditing standards.
We are sending copies of this report to other interested congressional
committees; the Postmaster General of the United States; and the Senior
Vice President and Federal Business Manager, Boise Office Solutions.
We will also make copies available to others upon request. In addition,
the report will be available at no charge on the GAO Web site at http:/
/www.gao.gov.
Please contact me at (202) 512-4841 or Michele Mackin at (202) 512-4309
if you have any questions regarding this report. Other major
contributors to this report were Penny Berrier, Art L. James Jr., Judy
T. Lasley, Sylvia Schatz, and Tatiana Winger.
Signed by David E. Cooper:
David E. Cooper
Director, Acquisition and
Sourcing Management:
[End of section]
Appendix I Comments from the U.S. Postal Service:
KEITH STRANGE:
VICE PRESIDENT, SUPPLY MANAGEMENT:
UNITED STATES POSTAL SERVICE:
December 13, 2002:
Mr. David E. Cooper:
Director, Acquisition and Sourcing Management United States General
Accounting Office Washington, DC 20548-0001:
Dear Mr. Cooper:
Thank you for providing the Postal Service with the opportunity to
review and comment on the draft report entitled, Contract Management:
Postal Service‘s National Office Supply Contract Has Not Been
Effectively Implemented. The report raises and confirms issues that we
are also concerned about and are working to address.
Strategic sourcing is universally recognized by industry and academia
as both a cornerstone of effective supply chain management and a cost
effective business strategy. The Postal Service‘s national contract for
office supplies was one of our first efforts to employ these business
strategies, and we believe we have achieved some real success,
especially considering the fact that office supplies had been purchased
on a local and regional basis for decades. While we agree the extent of
that success could be larger, it is always a challenge to change the
business practices of an organization the size of the Postal Service.
The business benefits of supply chain management and strategic sourcing
hold much promise for organizations like the Postal Service which face
continuing financial and competitive pressures. That is why we continue
to institutionalize them as our operating philosophy.
It is important to understand that, due to such factors as requirements
for Postal Service-unique items, we never intended for Boise Cascade to
fulfill all of the Postal Service‘s office supply requirements. In
addition, the data analyzed in the report is very broad, and includes
items that we do not categorize as office supplies (such as medical
supplies) and other office supply items (such as rubber bands and
envelopes) that may continue to be more effectively purchased under
separate contracts. These exceptions may skew perceptions as to the
overall effectiveness of the Boise Cascade contract. On the other hand,
we agree that the contract has been a significant contributor to
ensuring the Postal Service meets its obligations under the Javits-
Wagner-O‘Day Act (JWOD). There are over 800 JWOD items included under
this contract.
This contract was one of the earliest efforts to reap the benefits of
supply chain management, and has proven to be a valuable learning
experience. We have found the success of a contract of this scope is as
much an educational process as an operational one. Additionally, your
report reinforces that the success of this sort of contract requires
continuous management. This understanding was one of the motivations
for our recent restructuring of the Purchasing and Materials
organization into a new Supply Management organization. The new
organization is centered on dedicated and specialized category
management teams, including the Office Products and Equipment Category
Team. The team will be using the GAO report and its recommendations to
determine why the contract is not being used as fully as anticipated
and to develop and enforce policies aimed at improving performance
under the contract.
We appreciate GAO‘s efforts to quantify the extent of ’maverick“ (off-
contract) buying. We knew from our research on private sector strategic
sourcing that moving all category buying to the resultant contracts was
a continual challenge. In fact, research indicates that leakage at 30%
or even higher is typical. We certainly agree that contract compliance
can be improved, and we will continue to seek to find cost effective
ways to expand our oversight efforts. With the first nine months
primarily spent on implementation issues, the contract was not
considered fully rolled out until January 2001. Part of the plan to
improve contract compliance was to make our web based purchasing
system, eBuy, the central ordering process. eBuy has only been in place
since July 2001 with an implementation that is just now reaching a
point where it can be used by offices nationally. We anticipate that
new restrictions being placed on the use of credit cards and other
payment modes for items carried under this contract and the mandate to
use eBuy, will combine to improve compliance in this area.
We agree that the cost effectiveness of this contract should be
continuously monitored and measures for tracking savings can be
improved. The initial $28 million savings estimate included in your
report was based on market research and awarding a contract with $50
million in annual spend. Previously we could only rely on market
research and internal estimates for savings calculations; however,
through this contract, we can now establish baseline measurements on
which to improve our performance. Even though the report estimates that
the contract has provided $1 million in savings realized through
rebates and price reductions, our internal analysis has validated $5.3
million in cost reductions during fiscal year 2002 alone. Significant
additional administrative costs have also been avoided due to orders
being processed through eBuy versus more traditional and expensive
ordering processes, such as purchase orders.
Regarding our small, minority and woman owned business subcontracting
goals, we agree that there were some ambiguities in the contract
wording and these have been corrected. The Postal Service and Boise
Cascade realized from the start that the subcontracting goal would not
be easily attained. We did make an effort to work with Boise Cascade to
move subcontracting results closer to the original goal before
accepting that the goals needed to be re-established. The report
recognizes our efforts and changed circumstances in this area, and as
recommended, we will be working with Boise to establish more realistic
goals for subcontracting with small, minority and women owned
suppliers.
We appreciate the efforts and professionalism of your review team and
their report will help us to better capture the benefits of
strategically sourced volume leveraged contracts. If you or your staff
would like to discuss any of these comments further, I am available at
your convenience.
Sincerely,
Signed by Keith Strange:
[End of section]
Appendix II Comments from Boise Office Solutions:
BOISE*:
Office Solutions:
6745 Business Parkway Elkridge, Maryland 21075-6340:
January 9, 2003:
General Accounting Office ATN: Ms. Michele Mackin Room 4915:
441 G St., NW Washington, DC 20548:
Boise‘s Response To GAO‘s Analysis:
Of the LISPS National Office Supply Contract:
First, Boise wishes to recognize GAO‘s attention to the issue of
federal subcontracting (second tier) involving small, minority and
woman-owned (SMW) businesses. The lack of policy attention in Congress
and the executive branch to second tier partnering with SMW businesses
is a chronic deficiency and deprives the government of an efficient
job-creation mechanism. Specifically, Boise believes that second-tier
approaches allow federal contractors to mentor SMW manufacturers and
provide access to efficient distribution channels. In over 25 years as
a mentor of SMW manufacturers, Boise has witnessed many of these SMW
businesses providing meaningful jobs in distressed communities. Given
the advancements in federal procurement regulations (e.g., the Federal
Acquisition Streamlining Act) and enabling technology such as Internet
ordering systems, it is critically important that second-tier
contracting be developed as an vital link in new paradigms (e.g., JIT
delivery) involving supply chain management. This requires that the
government rethink its focus on small businesses as prime (first-tier)
vendors as the only approach. It seems possible - if not probable -
that mentoring SMW manufacturers will provide more jobs in local
communities than first-tier contractors who can qualify as a federal
prime through pass-through orders to federal agencies from wholesalers.
In the current environment, all first-tier sales to the federal
government from SMW distributors ’count“ toward federal small business
goals even if the items purchased by the government are produced by
large businesses. On the other hand, second tier sales only ’count“ if
the items are manufactured by SMW businesses. This makes it much more
difficult to achieve numerical goals. But are numerical goals the
appropriate focus? Isn‘t the creation of jobs and other economic
opportunities through federal dollars the real purpose of SMW goals?
Boise, as well as many other federal contractors, believe so and offer
the following points for consideration:
I) focus on rewarding agencies for subcontracting approaches that
reward job creation rather than the pursuit of pass-through dollar
approaches that may not have a demonstrable impact on job-creation
beyond the principal owner of the small distribution business. Job
creation has been utilized for decades by federal agencies to measure
success (e.g., JTPA, CEETA, EDA) so acceptable methodologies are
available. So why not use these tools with first and second tier
contracting? Not only would the results connect directly with job
creation and other public policy goals, but it would also allow first-
and second-tier approaches to be evaluated on an equal basis, i.e., job
creation.
2) determine the appropriate role of the government in managing the
small business subcontracting process. The GAO analysis of the USPS
national office supply contract mentions that USPS does not mandate
employees to purchase SMW produced items that are easily (and very
visibly) available from Boise. In fact, the federal government, as a
whole, does not mandate employees to purchase SMW-produced items in a
second-tier context.
This has several implications. First, the lack of a mandate indicates
that the federal government‘s stance on SMW second-tier purchases is
proscriptive in nature. In the case of the USPS office supplies
contract, a proscriptive approach implies that the vendor should strive
to achieve the highest level possible of SMW second-tier purchases. It
was in this context that Boise agreed to a ’stretch“ goal. Boise has a
highly developed second-tier program with catalog participation, active
mentoring and joint marketing available to all customers, including the
government. So, it is consistent with our culture to support ’stretch“
goals as a way to support our SMW manufacturers, as well as to develop
and grow internally.
Second, while the government will not mandate these purchases, the
government will at times become prescriptive in assigning
responsibility to vendors for achieving numerical goals with the
possibility of penalties should a shortfall occur. Now the vendor,
performing in a proscriptive environment in which the government will
not mandate purchases, is evaluated based on prescriptive, numerical
performance without the benefit of a government mandate.
Third, the gap between proscriptive and prescriptive approaches is
further exacerbated by other socioeconomic programs, such as the Javits
Wagner O‘Day Act, which mandates purchases of NIB/NISH items.In
practice, this means that SMW items deemed equivalent to NIB/NISH items
must be blocked from purchase. So, not only will the government not
mandate purchase of SMW items that are second tier, but also these
items must be blocked from purchase entirely if an equivalent NIB/NISH
item is identified.
These inconsistencies in policy in terms of first versus second tier,
and SMW versus NIB/NISH, discourage participation of SMW manufacturers
in the federal government arena. As a result, many opportunities to
market SMW items are missed along with opportunities to create more
jobs in local communities.
In conclusion, if the government intends to pursue a prescriptive
approach to evaluating vendor performance, then it is incumbent upon
the government to become involved in procurement policy that extends
beyond first tier set asides. Second tier offers synergies with supply
chain management and also offers effective job creation potential. The
infrastructure already exists to pursue this option more fully.
Analysis of GAO Audit Specifics:
In terms of responding to more specific points raised by the GAO
analysis, Boise offers the following clarifications:
1) The small business plan for the USPS office supplies contract
identifies goals as ’separate dollar and percentage goals for small,
minority and woman-owned business.“ This format of separate dollar and
percentage goals is consistent with the language contained in the USPS
office supplies solicitation.
Boise agreed to a plan based on a contract amount of $11 million. At
that contract amount, Boise agreed to 30% subcontracting with small
business and a $3,300,000 dollar goal. However, actual annual sales
have far exceeded the expected $11 million contract amount (which may
suggest that the implementation has been effective). If the contract
amount had been $50 million (the approximate actual sales), the
percentage goal would not have been 30% even as a stretch goal. Because
there are many more non-SMW items in the catalog than SMW items, if
both groups of items grow at the same rate, the overall percentage of
sales of SMW items will decline. In fact, the SMW items have grown
consistently through the period focused upon by the GAO audit:
[See PDF for image]
[End of figure]
[End of table]
However, despite the significant percentage of sales growth over the
three-year period above, the actual percentage of total sales declined:
[See PDF for image]
[End of figure
[End of table]
Thus, it is important to maintain tracking of the total amount of the
contract, dollar goods and percentage goals. In this case, the total
contract amount far exceeded the plan, which strongly influenced the
sales ratios between totals and SWM, as shown in the above examples. In
fact, actual dollar sales for fiscal year 2001 achieved 74% of the
dollar goal. If MOD sales were counted (a decision under consideration
at certain agencies), the dollar achievement is more than double the
dollar goal in the plan.
2) GAO indicates that the subcontracting (second-tier) plan was
’carelessly constructed.“ Boise agrees that greater involvement and
structure on the part of the government in developing subcontracting
plan methodologies would be helpful. This is particularly the case if
the government elects to take a hands-on prescriptive approach in the
evaluation stage.
In the case of the USPS contract, Boise utilized a Federal Acquisition
Regulation based format because it is a generally accepted standard.
The USPS agreed to this format. There were a few instances in the
boilerplate where the term ’small disadvantaged“ was used in place of
’minority.“ However, the correct terminology is utilized in the
headings and other instances throughout. Boise understands that the use
of ’minority business“ ’counts“ large minority business whereas ’small
disadvantaged business“ would not ’count“ a large minority business.
Again, the use of economic measures such as job creation would
alleviate conflicts about size standards and counting methodologies.
Boise has worked with USPS to correct inconsistencies in the formatting
and we thank GAO for pointing this out.
3)GAO indicates that ’recently Boise has begun to take actions to
improve results.“ Again, we thank GAO for recognizing our efforts to
continually improve performance. Actually, Boise conducted
implementation meetings at virtually every Postal District during which
the importance of purchasing SMW items was stressed. Additionally,
Boise utilized its existing infrastructure in which SMW items are
flagged throughout the catalog. Boise distributed a customized catalog
to approximately 40,000 Postal facilities which highlighted the SMW
items. During the first few months of the implementation, Boise
developed a regional program to promote purchases of SMW remanufactured
toners and repeatedly made this information available. Obviously, Boise
intends to continually do more to grow SMW sales, but we don‘t believe
we treated our SMW goals as a low priority. Again, the lack of a
mandate from the government to buy SMW items is a drawback,
particularly in a large, decentralized entity such as USPS.
4)GAO also questions the USPS/Boise contention that MOD items ’crowd
out“ opportunities for SMW products. While the actual number of SMW
items in the Boise catalog crowded out by MOD may not appear overly
extensive, the fact of the matter is that JWOD items are mandatory and
SMW items are not. New MOD items, once introduced, are evaluated
against SMW items. If the MOD and SMW items are considered ’essentially
the same“ by the government, the SMW items must be blocked from further
purchase.
As a result of blocking occurring over a period of years, many SMW
manufacturers simply focus their efforts elsewhere. Using a job
creation analogy, many SMW manufacturers would fall into the category
of the jobless who have become discouraged and no longer actively
pursue work. Thus, they are no counted if one simply inspects a current
catalog as the basis for analysis.
5)GAO also questions the USPS-Boise contention that replacing of IRT
paper rolls made by a small, woman-owned business, with paper rolls
(for a replacement machine for the IRT) made by a large business, had a
material impact on SMW second-tier performance. During the period in
question, from 2000-2001, USPS sales nearly tripled as result. Sales of
IRT items grew at less than twice the overall rate during this period.
Thus, the much slower growth of IRT paper tapes did have a negative
impact on SMW percentage goals because they grew more slowly than the
rest of the contract which ramped up quickly during the aggressive
national roll out.
We thank GAO for pointing out this opportunity, however, and are
continuing to search for a small business opportunity for the new paper
rolls.
6)GAO cites results of field visits in which USPS personnel indicated a
lack of awareness regarding USPS SMW contracting goals. We believe the
selection of field studies GAO is referring to was based on a listing
of Postal facilities which were low users of the contract. In fact,
Boise provided the list to GAO. Based on the low purchase volume in
this sample, we would expect such facilities to be unaware, or least
less aware. A random sample of all Postal facilities would provide a
much better perspective on the true level of awareness in the field.
Boise sales reps have, and will, contact USPS procurement contacts in
nearly every Postal District regarding the SMW program.
In this regard, Boise has a Captain assigned to every district. These
Captains are coordinated through a customized email and voicemail
number. A dedicated National Account Manager for the USPS leads this
effort. Additionally, Boise has a dedicated customer service queue to
taking USPS orders and handling customer service requests. All Boise
locations have National Account Coordinators available to assist postal
customers locally. Through new CRM technology, all USPS end users have
a specific PIN number which allows Boise to accurately follow each
request of an end user. Additionally, Boise has dedicated IT resources
to implement the Postal Service eBuy system, which allows all USPS end
users with Internet access to place orders electronically.
These capabilities and resources provide a true supply chain for USPS,
as well as its suppliers, which include SMW manufacturers. Many of the
cost reductions have yet to be quantified, but do in fact, exist. For
example, the ability of USPS to rely on JIT ordering rather than
utilize stock rooms provides huge savings. The new eBuy system has
automated the purchasing approval process which previously required a
costly manual review process. End users can now place orders
electronically with several vendors rather than recreating the
purchasing process each time they buy. This means they:
now have an order tracking process as well as a preapproved price.
Additionally, the eBuy system supports socioeconomic regulatory
compliance with JWOD and other procurement laws. The same could apply
to SMW purchases.
Overall, with a government mandate for purchasing SMW product similar
to the mandate for JWOD (NIB/NISH) items, the SMW program results would
improve markedly. Boise looks forward to continuing to be part of the
solution and a good corporate citizen. Again, we thank GAO for this
opportunity to address a long neglected topic.
Sincerely,
Signed by Mark Heuer:
Mark Heuer:
Federal Business Manager:
[End of section]
FOOTNOTES
[1] The high risk list identifies a federal program or operation that
is highly vulnerable to waste, fraud, abuse, and mismanagement or that
requires urgent attention to ensure that our national government
functions in the most economical, efficient, and effective
manner possible. U.S. General Accounting Office, U.S. Postal Service:
Major Management Challenges and Program Risks, GAO-01-262 (Washington,
D.C.: January 2001); U.S. General Accounting Office, U.S. Postal
Service: Deteriorating Financial Outlook Increases Need for
Transformation, GAO-02-355 (Washington, D.C.: Feb. 28, 2002);
U.S. General Accounting Office, U.S. Postal Service: Moving Forward
on Financial and Transformation Challenges, GAO-02-694T (Washington,
D.C.: May 13, 2002).
[2] In this report, ’fiscal years“ are Postal Service fiscal years,
which from 1999 through 2001 began in early-to mid-September.
[3] The awardee was formerly known as Boise Cascade Office Products.
[4] 15 U.S.C. Sect. 637c(2).
[5] 39 USC Sec. 201.
[6] The Javits-Wagner-O‘Day Act established a Committee for Purchase
from People who are Blind or Severely Disabled, which maintains a
procurement list of commodities or services that the government must
procure from designated nonprofit agencies. These agencies are
represented by central nonprofit agencies called the National
Industries for the Blind and the National Industries for the Severely
Handicapped (41 CFR ch. 51).
[7] The new option period expires on January 6, 2005. According to the
contracting officer, it was necessary to exercise the option in January
2003, rather than April 2003, to prevent the contract from lapsing.
[8] 41 U.S.C. sec. 48b(7).
[9] E-buy requires use of the intranet for placing orders. In the event
of a telephone or fax order, a Boise customer service representative
inputs the order.
[10] The Schedules program provides federal agencies with a simplified
process for obtaining commonly used commercial supplies and services,
ranging from office supplies to information technology services, at
prices associated with volume buying.
[11] Office of Inspector General, U.S. Postal Service, Supplier
Diversity Program for Supplies, Services, and Equipment Purchases, CA-
AR-01-005 (Arlington, VA: Sept. 6, 2001).
[12] The Postal Service has addressed only one of these
recommendations, noting in its April 2002 Purchasing Assessment Report
that fiscal year 1999 and 2000 data contained errors in SMW data.
[13] U.S. General Accounting Office, Contract Management: Government
Faces Challenges in Gathering Socioeconomic Data on Purchase Card
Merchants, GAO-03-56 (Washington, D.C.: Dec. 13, 2002).
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