TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION

 

 

Due to the Lack of Experienced Users, the Benefits of Performance-Based Acquisition Are Not Being Fully Realized

 

 

 

April 11, 2008

 

Reference Number:  2008-10-098

 

 

This report has cleared the Treasury Inspector General for Tax Administration disclosure review process and information determined to be restricted from public release has been redacted from this document.

 

Phone Number   |  202-622-6500

Email Address   |  inquiries@tigta.treas.gov

Web Site           |  http://www.tigta.gov

 

April 11, 2008

 

 

MEMORANDUM FOR DEPUTY COMMISSIONER FOR OPERATIONS SUPPORT

 

FROM:                            Michael R. Phillips /s/ Michael R. Phillips

Deputy Inspector General for Audit

 

SUBJECT:                    Final Audit Report – Due to the Lack of Experienced Users, the Benefits of Performance-Based Acquisition Are Not Being Fully Realized (Audit # 200710005)

 

This report presents the results of our review to determine whether the Internal Revenue Service (IRS) is effectively managing its use of performance-based acquisition (PBA) from preparation of performance work statements or statements of objectives through surveillance of service quality and performance.  The Director, Procurement, requested this audit.

Impact on the Taxpayer

When used properly, PBA increases performance, innovation, and competition among interested vendors and results in better value for the Federal Government.  In addition, it shifts much of the risk from the Federal Government to industry and allows the Federal Government to focus its monitoring efforts on the desired outcomes rather than on how the work is to be performed.  This saves taxpayer dollars because significantly fewer contract administration resources are needed.  However, we found the IRS consistently failed to meet the Office of Management and Budget (OMB) target achievement level for the use of performance-based methods.  This occurred because IRS program offices have not yet adopted the view that they are primarily responsible for identifying the requirements that may be suited for PBA and for doing their part in meeting the OMB goals for use.

Synopsis

Our review of a judgmental sample of seven contracts that used PBA methods showed that they were performed in accordance with established guidelines.  However, the IRS’ overall use of PBA is well below the goals established by the Federal Government.  A lack of internal expertise within program offices on how to implement PBA as an acquisition strategy, insufficient time to complete procurements, a lack of a vigorous planning phase, and the inability by program managers to define requirements contributed to the under use of PBA.

The Federal Acquisition Regulation[1] states that agencies must use PBA to the maximum extent practicable when acquiring services.  The OMB sets Federal Government-wide goals for the use of PBA for eligible service actions of more than $25,000.  For each of the Fiscal Years 2004, 2005, and 2006, the Federal Government’s goal was 40 percent.  The IRS achieved 18 percent, 22 percent, and 13 percent, respectively, for the 3 years.  Due to the tight time periods for completing procurements, which sometimes result from a lack of planning or the inability of program managers to define the requirements and desired outcomes of a contracting effort, the IRS Office of Procurement (Procurement) often must forego use of this acquisition strategy.  To determine why PBA was not used more often, we reviewed 20 acquisitions that Procurement advised us would have been good PBA candidates.  Only one Contracting Officer Technical Representative that we discussed these acquisitions with had had any formal PBA training.  We believe that this lack of knowledge, education, and experience within the business units is one of the primary barriers for not using PBA.  Because program offices, not Procurement, have the primary responsibility for defining requirements, we believe program office participation is essential to ensuring the effective use of PBA as a cost-effective business practice.

Recommendations

The Deputy Commissioner for Operations Support, with the support, assistance, and input from the Deputy Commissioner for Services and Enforcement, should ensure that program office management develops and implements a comprehensive plan to meet OMB goals for use of PBA methods.  These methods should emphasize the collective responsibility to plan, manage, and execute PBA with cross-organizational teams and with significant participation and contribution by program offices.  Further, if not already included, the insertion of PBA usage as a measure in individual performance standards may provide the necessary incentive to achieve PBA goals and advantages.  In addition, program personnel with the authority to select the acquisition strategy appropriate for the procurement and those involved in writing contract requirements should be trained in performance-based methods.  Program personnel should also consult with trained Procurement officials when deciding which type of procurement vehicle to choose to ensure that contract requirements are compatible with PBA.  Finally, the Director, Procurement, should continue to advocate and educate program personnel on the benefits of PBA.

Response

The IRS agreed with our recommendations.  The Deputy Commissioner for Operations Support has signed a memorandum for distribution encouraging program office management to emphasize the importance of using the PBA methodology to the maximum extent practicable and their collective responsibility in planning, managing, and executing PBA.  The memorandum urges program personnel and Contracting Officer Technical Representatives to become familiar with the “Seven Steps to Performance Based Acquisition” guide and to enroll in a PBA course.  Among other initiatives, PBA will be identified as a High Priority Initiative requiring a detailed plan for improvement that identifies activities with scheduled start and completion dates and is updated and reported monthly to the Deputy Commissioner for Operations Support.  However, IRS management believes inclusion of PBA use in performance standards should be at the discretion of business unit managers.

Procurement will continue to provide training opportunities for program office personnel through the Treasury Acquisition Institute but cannot require attendance at those courses.  Individual managers make the determination based on employees’ assignments and developmental needs.  In addition, the Advance Acquisition Planning Council will continue to emphasize and discuss development of PBA work statements with project managers in Advance Acquisition Planning Meetings for requirements supporting major and nonmajor investments.

Finally, Procurement has generated an action-forcing event memorandum that emphasizes the requirement for all program officials to use PBA strategies to the maximum extent practicable and the many opportunities offered by Procurement to learn about PBA.  As a result, the Office of Procurement Policy has revised its policy and procedures to include a new requirement for an acquisition planning meeting with the Director, Procurement, for any contract action, other than firm-fixed price, that exceeds $10 million.  Management’s complete response to the draft report is included as Appendix IV.

Copies of this report are also being sent to the IRS managers affected by the report recommendations.  Please contact me at (202) 622-6510 if you have questions or Nancy A. Nakamura, Assistant Inspector General for Audit (Headquarters Operations and Exempt Organizations Programs), at (202) 622-8500.

 

 

Table of Contents

 

Background

Results of Review

Efforts to Implement Performance-Based Acquisition Have Fallen Short of Federal Government Goals

Recommendation 1:

Program Offices Lack Knowledge, Education, and Experience in the Use of Performance-Based Acquisition

Recommendations 2 and 3:

Appendices

Appendix I – Detailed Objective, Scope, and Methodology

Appendix II – Major Contributors to This Report

Appendix III – Report Distribution List

Appendix IV – Management’s Response to the Draft Report

 

 

Abbreviations

 

FY

Fiscal Year

IRS

Internal Revenue Service

OMB

Office of Management and Budget

PBA

Performance-Based Acquisition

 

 

Background

 

The Internal Revenue Service (IRS) uses a variety of approaches to obtain goods and services.  One type of procurement, Performance-Based Acquisition (PBA), has begun to receive increased emphasis and priority within the Federal Government because it can increase performance, innovation, and competition among interested vendors, resulting in better value for the Federal Government.  PBA is a method for structuring all aspects of an acquisition around the need and outcome desired as opposed to the method by which the work should be done.  For example, a need is identified for janitorial services with the desired outcome of clean office spaces.  However, the Federal Government does not detail how the janitorial work should be done.  This type of procurement shifts much of the risk from the Federal Government to industry because contractors become responsible for achieving the objectives in the work statement using their own best practices.  It also allows the Federal Government to focus its monitoring efforts on the desired outcome–rather than on how the contractor performs the work–resulting in significantly fewer contract administration resources.

The Federal Acquisition Regulation states that agency program officials are responsible for accurately describing the need to be filled or problem to be resolved through service contracting in a manner that ensures full understanding and responsive performance by contractors and, in so doing, should obtain assistance from contracting officials, as needed.  The Federal Acquisition Regulation further states that to the maximum extent practicable, the program officials shall use PBA methods when describing the need to be filled.

In 2001, the Office of Management and Budget (OMB) issued a mandate specifically directing agencies to write performance-based methods on a specific percentage of the total eligible service contracting dollars worth more than $25,000.

On September 7, 2004, the OMB issued another memorandum to Federal agencies requiring the application of PBA methods on 40 percent, as measured in dollars, of eligible service actions of more than $25,000, including contracts, task orders, modifications, and options awarded in Fiscal Year (FY) 2005.

On July 21, 2006, the OMB issued an additional memorandum extending the 40 percent requirement to FY 2006.  Further, the memorandum requested that agencies submit a PBA Management Plan by October 1, 2006.  On May 22, 2007, the OMB stated in a memorandum that most agencies met or exceeded the FY 2006 goal, awarding more than 45 percent of their eligible service contracts as performance-based.  The memorandum set a 45 percent goal for FY 2007.

In addition, on April 25, 2007, the OMB issued a memorandum, The Federal Acquisition Certification for Program and Project Manager, which established a structured development program for project and program managers that includes modules for PBA.  The program is required for project and program managers assigned to what are considered major acquisitions.

This audit was performed at the Office of Procurement (Procurement) in the Office of Agency-Wide Shared Services in Oxon Hill, Maryland, during the period March through November 2007.  We conducted this performance audit in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective.  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective.  Detailed information on our audit objective, scope, and methodology is presented in Appendix I.  Major contributors to the report are listed in Appendix II.

 

 

Results of Review

 

While the IRS has never achieved the recommended PBA usage levels, we determined that the procurements in which PBA was used were performed in accordance with guidelines.  Our review of a judgmental sample of seven PBA contracts showed that the two primary processes of 1) acquiring services and 2) ensuring contract monitoring were performed in accordance with Federal Acquisition Regulation guidelines.  Specifically, the performance requests sent to prospective contractors were prepared in accordance with the guidelines and generally used a statement of objectives prepared by the IRS.  The contractors then prepared a performance work statement as part of their proposals.

The contractors also submitted adequate quality assurance plans[2] in conjunction with the solicitations, usually in the form of a matrix showing required services, performance measures, acceptable quality levels, monitoring, and methods.  All of the Contracting Officers and Contracting Officer Technical Representatives[3] associated with these seven procurements had training in PBA use.

However, the IRS’ overall PBA use was consistently low.  We determined that there were several possible reasons for this, including a lack of knowledge, education, and experience within the business unit staff of how and when to use this type of procurement technique, a lack of vigorous planning, and insufficient time for Procurement to award the contract using PBA.  As a result, the IRS has not achieved the desired usage rates and may not have made the best use of its resources when acquiring goods and services.

Efforts to Implement Performance-Based Acquisition Have Fallen Short of Federal Government Goals

The IRS has consistently missed OMB goals for PBA use.  Figure 1 shows the IRS’ actual performance for eligible service dollars according to its management plan as of October 1, 2006.

Figure 1:  Percentage Use of
Performance-Based Acquisition

Fiscal Year

OMB Goal

(Percentage)

IRS Actual

(Percentage)

2001

10%

4.78%

2002

20%

12%

2003

30%

7.37%

2004

40%

18%

2005

40%

22%

2006

40%

13%

                                                       Source:  October 1, 2006, PBA Management Plan.

In response to an OMB requirement, IRS senior Procurement executives submitted a PBA usage plan in October 2006.  In the plan, they describe their outreach efforts to program offices (e.g., IRS business units) and the ongoing encouragement they provide to Office Directors and Branch Chiefs to use performance-based requirements to the maximum extent practicable.  For years, IRS Procurement has emphasized the use of PBA to program officials through the advance acquisition planning process.  In the most recent annual memorandum dated July 12, 2007, the Director, Procurement, reemphasized the need for the IRS to make greater use of the PBA methods in their statements of work and contracts for services.  The memorandum notes that OMB Circular A-11, Preparation, Submission, and Execution of the Budget, makes it mandatory for Federal Government agencies to use performance-based work statements for information technology services contracts that support major investments.  The memorandum further states that failure to use the PBA methods must be justified in the acquisition plan and will result in a poor evaluation of the acquisition strategy section of the Exhibit 300, Capital Asset Plan and Business Case Summary, when it is reviewed by management for funding.  However, because Procurement developed and implemented the PBA usage plan, it only addressed the actions it planned to take to increase IRS use of PBA.  There was no corresponding plan developed by the IRS business units. 

The decision to use a performance-based approach to obtain services is a shared responsibility between Procurement and the business units.  This decision has to be made upfront.  Notwithstanding Procurement’s efforts, we believe that top-level program office management participation is essential to ensure that the economic and program benefits of PBA are realized as directed by the Federal Acquisition Regulation, and to ensure that OMB goals are met.  Program offices have the mission needs, fund the acquisitions, and most importantly have the primary responsibility for defining service requirements that meet these mission needs.  Program offices have not yet adopted the view that they are responsible for identifying requirements that may be suited for PBA and for doing their part in meeting the goals for use.  The OMB performance goal is primarily assigned to Procurement.  However, Procurement cannot determine the acquisition method and the schedule, including the contract type that can incorporate PBA methods, unless the program office has done its part before submitting the acquisition request.  The program offices should be:

  • Identifying requirements that may be suited for PBA and meeting with the contracting office and any other stakeholder.
  • Developing the performance work statement or the statement of objectives, acceptable quality levels, and a plan to monitor performance.
  • Obtaining training in PBA as a team to ensure that everyone understands the concepts and goals.
  • Performing market research to identify sources that could provide what is needed and learn as much as possible about the industry’s commercial practices.

The IRS has no comprehensive plan to meet OMB goals that emphasize the collective responsibility to plan, manage, and execute PBA with well-trained, cross-organizational teams comprised of representatives from budget, technical, contracting, logistics, and legal staff and with significant participation and contribution by program offices.  Senior IRS executives can support these efforts by working to overcome resistance, organizing resources, and building commitment to new ways of doing business.  Until business units are held accountable for identifying requirements that may be suited for PBA and for doing their part to embrace this acquisition strategy, the percentage usage goal set by the OMB and the economic and program benefits of PBA will not be achieved.

Recommendation

Recommendation 1:  The Deputy Commissioner for Operations Support, with the support, assistance, and input from the Deputy Commissioner for Services and Enforcement, should ensure that program office management develops and implements a comprehensive plan to meet OMB goals for use of PBA methods.  These methods should emphasize the collective responsibility to plan, manage, and execute PBA with cross-organizational teams and with significant participation and contribution by program offices.  Further, if not already included, the insertion of PBA usage as a measure in individual performance standards may provide the necessary incentive to achieve PBA goals and advantages.

Management’s Response:  The IRS agreed with the recommendation.  However, management believes inclusion of PBA usage in performance standards should be at the discretion of business unit managers.  The Deputy Commissioner for Operations Support has signed a memorandum for distribution encouraging program office management to emphasize the importance of using PBA methodology to the maximum extent practicable and their collective responsibility in planning, managing, and executing PBA.  The memorandum states both the OMB and the Department of the Treasury goals for PBA and identifies a number of training opportunities recommended for program staff and Contracting Officer Technical Representatives.  Among other initiatives, PBA will be identified as a High Priority Initiative requiring a detailed plan for improvement that identifies activities with scheduled start and completion dates, and is updated and reported to the Deputy Commissioner for Operations Support monthly.

Program Offices Lack Knowledge, Education, and Experience in the Use of Performance-Based Acquisition

To determine why the IRS did not use PBA more often, we selected a sample of 20 nonperformance-based acquisitions from a list provided by Procurement that may have been appropriate for PBA contracting.  We interviewed the responsible Contracting Officer Technical Representatives and, at the program offices’ request, other individuals involved with the contract to determine why the contracts were not requested to be performance based.

Of the 20 acquisitions reviewed, 2 did not appear to be suitable for PBA.  This was because the contracts involved changes in tax laws that required specific corresponding changes in processing software.  The contractors involved with these requirements worked closely with, and under the supervision of, IRS employees to accomplish the changes in the short time period available to them.  In addition, we noted that two additional acquisitions on the list were in fact performance-based contracts and should not have been listed.  We agree with Procurement that the remaining 16 acquisitions were suitable for PBA.

Based on our discussions, we determined that the primary reasons for not using PBA were a lack of knowledge, education, and experience in the use of this contract administration tool.  For example, of the 20 Contracting Officer Technical Representatives interviewed, only one had formal training in PBA; however, this training was 3 years ago.  In contrast, all of the Contracting Officers in Procurement that we interviewed for the 20 acquisitions had received PBA training.  Although we did not interview other individuals in the business units who were involved in the upfront planning of these acquisitions (and who could have made the decision to use PBA methods), we believe the IRS is not training all the right people on how to do PBA.  This may have occurred because OMB policy and the Federal Acquisition Regulation are based on contracting structures, so the Contracting Officers take the majority of the contracting training, including PBA.  Yet, in the IRS, the business units, not the Contracting Officers, perform the job analysis and technical document development (e.g., performance work statement or statement of objectives, quality assurance plan).  As a result, training only the Contracting Officers is not sufficient to increase the use of PBA.

Training is a critical tool in successfully implementing change.  To deliver training effectively, the IRS must prioritize acquisition initiatives that are most important to it, identify those needing training and set requirements, and ensure that its training reaches the right people.  Unless IRS management sets PBA training as a high priority and defines those employees who would be targeted for training (e.g., those who are involved in the upfront planning for major service acquisitions), the IRS will continue not to realize the benefits of this unique, innovative, and cost-effective way of managing contracts.  We believe Procurement could assist the business units in identifying the individuals who should receive this training first.

Recommendations

Recommendation 2:  The Deputy Commissioner for Operations Support, with the support, assistance, and input from the Deputy Commissioner for Services and Enforcement, should ensure that program personnel with the authority to select the acquisition strategy appropriate for the procurement and those involved in writing contract requirements be trained in performance-based methods.  In addition, program personnel should consult with trained Procurement officials when deciding which type of procurement vehicle to choose to ensure that contract requirements are compatible with PBA.

Management’s Response:  The IRS agreed with the recommendation.  A memorandum for distribution has been issued by the Deputy Commissioner for Operations Support and identifies several training opportunities and urges program personnel and Contracting Officer Technical Representatives to become familiar with the “Seven Steps to Performance Based Acquisition” guide and to enroll in a PBA course.  In response to a Memorandum for Bureau Chief Procurement Officers issued by the Department of the Treasury’s Senior Procurement Executive, Office of the Procurement Executive, the Director, Procurement, has mandated that all contracting 1102 series employees are required to complete a PBA training course.

Procurement will continue to provide training opportunities for program office personnel through the Treasury Acquisition Institute but cannot require attendance at those courses.  Individual managers make the determination based on employees’ work assignments and developmental needs.

The Advance Acquisition Planning Council will continue to emphasize and discuss development of PBA work statements with project managers in Advance Acquisition Planning Meetings for requirements supporting major and nonmajor investments.  The Advance Acquisition Planning Council works with the customer (e.g., project officers, program managers, Contracting Officer Technical Representatives) and the responsible procuring office Contract Specialist/Contracting Officer to develop a high-level acquisition strategy that includes determining procurement methodology such as PBA.

Recommendation 3:  The Director, Procurement, should continue to advocate and educate program personnel on the benefits of PBA and identify the program personnel who should receive the training first.

Management’s Response:  The IRS agreed with the recommendation.  Procurement has generated an action-forcing event memorandum that emphasizes the requirement for all program officials to use PBA strategies to the maximum extent practicable and the many opportunities offered by Procurement to learn about PBA.  As a result, the Office of Procurement Policy has revised its policy and procedures to include a new requirement for an acquisition-planning meeting with the Director, Procurement, for any contract action, other than firm-fixed price, that exceeds $10 million.  Procurement is currently assessing the training needs of individual program personnel for enrollment in the team-based PBA training that the Department of the Treasury is offering.

 

Appendix I

 

Detailed Objective, Scope, and Methodology

 

Our overall objective was to determine whether the IRS is effectively managing its use of PBA from the preparation of performance work statements or statements of objectives through surveillance of service quality and performance.  To accomplish this objective, we:

I.          Determined the criteria used by the IRS to select procurements suitable for PBA.

A.  Reviewed policies and procedures related to awarding PBA, including IRS policies, OMB guidelines, and Office of Federal Procurement Policy issuances.

B.  Interviewed IRS Senior Procurement management and other Procurement personnel to discuss their concerns and what contracts, if any, they recommended for review.

C.  Selected a judgmental sample of 7 performance-based service acquisitions awarded in FYs 2005 and 2006 from 283 open acquisitions.  We used a judgmental sample to ensure that the most significant PBA contracts were selected.

D.  Interviewed Contracting Officers and Contracting Officer’s Technical Representatives involved with the contracts in our sample to obtain an understanding of their responsibilities.

II.        Determined the extent to which the IRS uses PBA as required by OMB guidelines.

A.  Confirmed that the acquisitions in the judgmental sample in Step I.C. met the criteria for performance-based acquisition.

B.  Verified the accuracy of the IRS’ October 1, 2006, PBA Management Plan, which reported achievement levels of 22 percent and 13 percent, respectively, for FYs 2005 and 2006.

C.  Through reviews of selected contract files and discussions with responsible IRS officials, determined why the IRS did not meet OMB achievement levels of 40 percent for FYs 2005 and 2006.  We accomplished this through a judgmental sample of 20 acquisitions identified by Procurement as being eligible for a performance-based acquisition, though they were not.

This audit did not include audit procedures to obtain evidence that computer-processed data, which were the basis for our 2 judgmental samples (7 and 20), were valid and reliable.  Though used during this audit, the data in general were not considered significant to the audit’s objective or resultant findings.  We only used the data to reasonably verify the universe from which we selected our samples for substantive testing.  We only concluded and reported on those substantive tests.  Therefore, there was no adverse effect on the audit as a result of not including the reliability of computer-processed data audit procedures.

III.       Determined whether the IRS prepared complete, accurate, and timely performance work statements or statements of objectives for PBA contracts.

A.  For performance work statements, verified whether the statements were written as a description of required results rather than a description of how the results are to be attained.

B.  Verified whether the statements contained language to enable an assessment of work performance against measurable performance standards.

C.  Verified whether the statements used measurable performance standards and financial incentives in a competitive environment to encourage competitors to develop and institute innovative and cost-effective methods of performing the requested work.

D.  For statements of objectives, verified whether the objectives described the full size and range of the services required.

E.   Verified whether the objectives included measurable, mission-related objectives.

F.   Verified whether the objectives identified any constraints related to the services required.

IV.       Determined whether the IRS effectively prepared quality assurance surveillance plans and used them to evaluate contractor quality, performance, and conformity with the terms of the contracts and requirements of the Federal Acquisition Regulation.

A.    Identified the work that required surveillance.

B.     Verified whether the quality assurance surveillance plan was complete.

C.     Verified whether the quality assurance surveillance plan addressed both the contractor’s role in quality control and the Federal Government’s role in quality assurance.

D.  Identified the methods of surveillance used (e.g., sampling, periodic inspection, customer feedback, observation).

E.   Analyzed the sufficiency of documented surveillance schedules, checklists, and reports.

F.   Verified whether appropriate actions were taken to resolve incomplete or unacceptable work identified using the quality assurance surveillance plan.

 

Appendix II

 

Major Contributors to This Report

 

Nancy A. Nakamura, Assistant Inspector General for Audit (Headquarters Operations and Exempt Organizations Programs)

Alicia P. Mrozowski, Director

Thomas J. Brunetto, Audit Manager

Robert W. Beel, Lead Auditor

Chinita Coates, Auditor

Rashme Sawhney, Auditor

 

Appendix III

 

Report Distribution List

 

Commissioner  C

Office of the Commissioner – Attn:  Acting Chief of Staff  C

Deputy Commissioner for Services and Enforcement  SE

Chief, Agency-Wide Shared Services  OS:A

Chief Information Officer  OS:CIO

Director, Procurement  OS:A:P

Chief Counsel  CC

National Taxpayer Advocate  TA

Director, Office of Legislative Affairs  CL:LA

Director, Office of Program Evaluation and Risk Analysis  RAS:O

Office of Internal Control  OS:CFO:CPIC:IC

Audit Liaisons: 

           Deputy Commissioner for Operations Support  OS

           Deputy Commissioner for Services and Enforcement  SE

           Chief, Agency-Wide Shared Services  OS:A:F

           Modernization and Information Technology Services  B:TAM

           Director, Procurement  OS:A:P

 

Appendix IV

 

Management’s Response to the Draft Report

 

The response was removed due to its size.  To see the response, please go to the Adobe PDF version of the report on the TIGTA Public Web Page.



[1] Subpart 37.1 – Service Contracts – General, Section 37.102, (a). Policy (2001).

[2] In Federal Government contracting, Quality Assurance refers to the various functions, including inspection, performed to determine whether a contractor has fulfilled its contract obligations pertaining to quality and quantity.

[3] The Contracting Officer Technical Representative is responsible for monitoring the contract after award and has no role in determining the acquisition strategy.