401.2 - Acquisition Management Reviews

8/30/93

OPR: Admin/Procurement and Contracts

1. Purpose. This Survey Manual Chapter establishes an Acquisition Management Review (AMR) program within the U.S. Geological Survey (USGS). The goal of the AMR program is to ensure the quality, effectiveness and efficiency of the USGS procurement system through review and evaluation of organizational components exercising delegated procurement authority.

2. Authority.

A. Executive Order 12352, Federal Procurement Reform, Section 1(i).

B. Office of Management and Budget (OMB) Circular A-123, Internal Control Systems.

C. Department of the Interior (DOI) Acquisition Regulation 1401.7102, Acquisition management reviews.

3. Definitions.

Level 1 AMR is an AMR of the Administrative Division, Office of Procurement and Contracts (OPC), conducted by DOI.

Level 2 AMR is an AMR of an Administrative Division regional procurement office, conducted by OPC.

Level 3 AMR is an AMR of a division field office exercising delegated procurement authority conducted by the cognizant Administrative Division procurement office.

4. Policy.

A. Frequency. AMR's will be conducted on USGS organizational components exercising delegated procurement authority at least once every 4 years. AMR's may be combined with other procurement activities such as training courses, conferences, etc., to minimize travel and personnel costs.

B. Scope. AMR's will encompass evaluation of contracts and purchases using small purchase procedures for compliance with applicable laws, regulations, Executive Orders, GAO decisions, and sound business practices. Where applicable, review of assistance awards (grants and cooperative agreements) will be accomplished concurrently. Reviews will also address other areas affecting procurement, such as support for procurement programs, achievement of established goals and management objectives, problem identification and proposed solutions, areas of excellence, organization, and personnel utilization and training. Reviews will be conducted in accordance with general guidelines given in the most current edition of the Department of the Interior Acquisition Management Review Handbook.

C. Management Support. Management officials at offices delegated procurement authority have a continuing responsibility to ensure that this authority is exercised properly. For this reason, the AMR process will not be considered complete until documented deficiencies have been corrected or resolved.

5. Responsibilities.

A. The Assistant Director for Administration, as the Head of the Contracting Activity (HCA), is responsible for establishment and oversight of the U.S. Geological Survey's Acquisition Management Review program.

B. The Chief, Office of Procurement and Contracts (OPC) is responsible for conducting Level 2 AMR's, and implementing corrective action to Level 1 AMR's, as required.

C. The Chief, Headquarters Small Purchases Branch is responsible for conducting Level 3 AMR's of division field offices within his/her geographic area of authority.

D. The Chiefs of Regional Procurement and Contracts Branches are responsible for conducting Level 3 AMR's of division field offices within their geographic area of authority, and for implementing corrective action to Level 2 AMR's, as required.

E. Chiefs of division field offices delegated procurement authority are responsible for implementing corrective action to Level 3 AMR's, as required.

6. Procedures. The procedures following apply to Level 2 and 3 AMR's conducted by Administrative Division procurement offices. Level 1 AMR's are governed by guidance issued by DOI.

A. Pre-review.

(1) Reviewing office responsibilities:

(a) AMR Scheduling. Offices responsible for conducting AMR's will ensure field offices under their cognizance are reviewed at least once every 4 years. Fiscal year schedules of AMR reviews will be prepared and copies submitted to the Chief, OPC, and Procurement Policy Branch annually by December 15. Follow-up reviews will be distinguished from regular AMR reviews in the schedule. Schedule holders will be promptly notified of any changes in the schedule; i.e., rescheduled dates, added regular or follow-up reviews, etc.

(b) Advance Notification. Organizational components to be reviewed will be notified of a pending AMR at least 6 weeks in advance. Advance notice will include as much information as possible about the areas to be reviewed, the number of reviewers, duration of review, and documents required to be furnished in advance and at the entrance briefing.

(c) Determining team size and duration of review. The number of team members and duration of the review will be determined based on consideration of the following factors:

(i) Level of procurement authority exercised in the office and number of warranted contracting officers.

(ii) Total dollar volume and number of actions awarded, noting any significant changes in workload since last review.

(iii) Time available for review, impact on workload of office being reviewed and office(s) providing review team members.

(iv) Outcome and recency of previous review.

(v) Special topics needing attention, such as recent legislation or significant regulatory changes, Departmental or Geological Survey policy requirements, and current procurement management concerns.

(d) Selecting team members. The evaluation will be conducted by procurement professionals from the cognizant Administrative Division procurement office. The team may include representatives from other Administrative Division procurement offices or (Level 3 AMR's only) other division field offices, if appropriate. A team leader will be assigned.

(2) Responsibilities of office to be reviewed: The office to be reviewed will submit documents requested by the review team by the date(s) stipulated. A copy of the local organizational chart identifying personnel involved in procurement matters should also be provided to the reviewing office in advance of the review. Appropriate space and office supplies will be made available to the review team during the review.

B. Conduct of Review. The review will proceed according to the following schedule of events:

(1) An entrance interview will be held with the chief of the office reviewed and appropriate staff members to identify areas under consideration, introduce team members, discuss results of previous reviews, and mutually select procurement officials and, if appropriate, technical personnel to be interviewed.

(2) Personnel interviews will be conducted as required, and scheduled with minimum disruption to ongoing activities.

(3) Procurement documents will be reviewed to insure compliance with existing laws, regulations, USGS policy and procurement authority delegations.

(4) Procurement data and reporting systems will be reviewed to evaluate the accuracy of award data and to verify compliance with applicable reporting requirements.

(5) Review findings, whether adverse, commendable, or improvements from the previous review, will be evaluated to determine the overall quality of the procurement operation reviewed.

(6) Corrective action will be determined based on the number, type, and severity of adverse findings. A caution to comply with regulations in the future is not an adequate corrective action. Actions must be designed to improve the process or educate employees to prevent recurrence. Where a field office exhibits numerous significant deficiencies, corrective action will include scheduling a follow-up review within the next 12-18 months and/or sending procurement personnel to the next scheduled warrant maintenance training (Level 3 AMR's only). Reviews that disclose continued lack of improvement (repeat findings), or abuses of purchasing authority may result in suspension or revocation of the purchasing authority of the office reviewed.

(7) An exit interview will be conducted with the office chief and appropriate staff members to discuss the findings of the evaluation team, to recommend corrective action to adverse findings, and to assess the overall status of the procurement operation reviewed.

C. Post-review. The following procedures apply to Level 3 AMR's only. For Level 2 AMR's, the procedures of the DOI Acquisition Management Review Handbook apply.

(1) Reporting. A report summarizing the AMR findings and recommended corrective action for adverse findings will be prepared within 60 days of the review. The report will be addressed to the chief of the office reviewed through a management official one level above the addressee. Copies will be furnished to the regional Administrative Officer and the Chief, OPC. The Chief, OPC, will forward reports requiring follow-up reviews or suspension/revocation of an office's purchasing authority to the Assistant Director for Administration.

(2) Report responses. Within 30 days after receiving an AMR report, the chief of the office reviewed will submit a written response to the reviewing office reporting corrective action taken or planned to resolve adverse findings. The response will be routed through the management official identified above. Copies of the response will be furnished to the same officials who received copies of the AMR report. Disputed adverse findings which cannot be resolved between the chief of the office reviewed and the report author will be referred to the Chief, OPC.

(3) Follow-up reviews, reports and responses. Follow-up reviews will be conducted according to the procedures of paragraph 6B above, but will focus on adverse findings from the initial AMR, whether or not corrective actions have been taken, and their effectiveness. Reports of and responses to follow-up reviews will be prepared according to paragraphs 6C(1) or 6C(2) above, but will be readily distinguishable from regular reviews. Additional follow-up reviews may be required until all outstanding deficiencies are eliminated or resolved.