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Government and People
DISTRICT OF COLUMBIA
CONTRACTING AND PROCUREMENT TASK FORCE
CREATED PURSUANT TO THE CONTRACTING AND PROCUREMENT REFORM TASK FORCE ESTABLISHMENT EMERGENCY ACT OF 2005
December 4, 2006
To: The Hon. Vincent Orange, Chair, Committee on Government Operations Council of the
District of Columbia
The District of Columbia Contracting and Procurement Reform Task Force was established to make recommendations to the Mayor and Council to “improve the District’s contracting and procurement laws and regulations.”1 The Task Force was comprised of 7 experts in government procurement with government and private sector experience in both District and Federal contracting appointed by the Council, 2 representatives of Chief Procurement Officer and 1 representative of the Chief Financial Officer.2
The Task Force concludes that the problems in the procurement system are not in its laws, regulations and implementing procedures, but rather in the commitment of the government to train its personnel and to follow existing rules and generally recognized best practices.
Under existing law in the District,3 “‘[p]rocurement’ means acquisition.”4 "Acquisition" is defined to mean “the obtaining by contract of property, supplies, and services (including construction) by and for the District through purchase or lease, whether the supplies or services are already in existence or must be created, developed, demonstrated, and evaluated, and includes the establishment of agency needs, the description of requirements to satisfy agency needs, solicitation of sources, award of contracts, contract financing, contract performance, contract administration, and those technical and management functions directly related to the process of fulfilling agency needs by contract.”5 Of necessity, “acquisition” must include “acquisition planning.” Although the PPA does not define acquisition planning, it is described in the Federal Acquisition Regulation (“FAR”) as “the process by which the efforts of all personnel responsible for an acquisition are coordinated and integrated through a comprehensive plan for fulfilling the agency need in a timely manner and at a reasonable cost. It includes developing the overall strategy for managing the acquisition.”6 The Task Force reviewed the entire acquisition process, including acquisition planning.
The acquisition process is the means by which the government secures goods and services from the private sector, which it either cannot produce or provide with government employees or cannot produce or provide as efficiently as the private sector. Use of the private contractors to support or perform public functions permeates nearly every aspect of government activity. These contractors are often unrecognized by the public, and, if the contracts are performed without incident, are often invisible. But acquisition is not an end in itself; rather, acquisition either supports or implements governmental objectives. Contracts may provide material and service used in producing an end product delivered by government employees, such as providing vaccine to be administered by government employees at a government operated clinic, or may provide for complete delivery by the contractor to the public, as in a District funded, but privately operated, clinic. Government employees may work in contractor facilities, such as rented buildings, or contractors may be housed within completely government controlled facilities, such as the medical clinic within the jail. On the other hand, a large part of the District’s contracting is very apparent. Building guards throughout government buildings wear uniforms showing the name of their employers, which are contractors. A large share of street paving and repair is performed by clearly designated contractor equipment.
The license plate issued by the Department of Motor Vehicles is manufactured by a contractor. Income tax forms received by taxpayers are printed and mailed by contractors, and, if the taxpayer files his or her return by mail with a check in payment of taxes owed, the check will be processed and negotiated by a contractor before the funds are paid to the government. Few in the public consider that these quintessential governmental functions are not performed by the Government but are, in fact, performed by contractors. Although procurement, that is soliciting and awarding a contract, may be the final step in the acquisition process for each of these activities, the process is intertwined in general administration and policymaking. And after award, the procurement involves contract financing, contract performance and contract administration.
The District has had effective control over its procurement functions for the nearly four decades since President Johnson replaced the commissioner form of government with an appointed mayor-council government7 and full legislative control since the Congressional establishment of the elected government under the Home Rule Act.8 The Council enacted the PPA as a comprehensive revision of the law governing procurement practices in 1986, and the procurement regulations were comprehensively revised in 1988.9 In 1997, procurement functions were consolidated within the Office of Contracting and Procurement (“OCP”) under the direction of a statutory Chief Procurement Officer (“CPO”).10
There are no magic formulas which can ensure an effectively functioning procurement system. While experts may argue over nuances, many regulatory schemes, if followed, can achieve basically fair and cost-effective contracting which meet the government’s supply and service needs. An effective system requires transparency and consistent and assured timely application of established procedures. The current statutory and regulatory framework governing procurement in the District is based on similar Federal statutes and regulations. Although there are other models of procurement regulation, such as the American Bar Association Model Procurement Code,11 the Task Force believes that since many local businesses and professionals deal with both the District and Federal governments, there are public and private efficiencies to be achieved through conformity with Federal procurement practices. Notwithstanding that the District has not updated its statutes and regulations with changes made by the Federal Government of its own regulations after adoption of the PPA and District procurement regulations, there are no significant deficiencies the District’s procurement framework which would cause the procurement system, if its requirements were followed, to be dysfunctional.12 The critical problem in the District system is the failure to establish a climate of compliance and enforcement of controls that insure compliance with the existing procurement regulation system.
The District procures approximately $3.75 billion by contract through approximately 21,000 contracts each year. The clear majority of this amount is procured in accordance with the law and regulations without incident. Nevertheless, a substantial portion of this amount is known to be in violation of procurement procedures, indicating a lack of controls to insure compliance with the procurement law and regulations.
On behalf of the Task Force, the Government Contracts Program of the George Washington University School of Law under the direction of Professor Christopher Yukins reviewed 46 reports dealing with procurement issued by the District of Columbia Auditor since 1996 (19 reports) and the Inspector General since 2002 (27 reports). The reports cover a small sample of total procurement; yet they found a litany of procurement deficiencies ranging from lack of planning,13 improper sole source awards,14 failure to follow competitive procedures,15 contracting without authority,16 failure to assign personnel to oversee contracts,17 failure to document actions and payments,18 and failure to maintain records.19 What stands out, however, in the reports which were reviewed is that the auditors did not cite a single deficiency in the PPA and regulations implementing the PPA or recommend any modifications of the generally applicable procurement law.20 Every one of the numerous procurement actions questioned resulted from violation of existing procurement requirements, which, if followed, would have prevented the abuse.
Many of the inappropriate procurement actions noted in audit reports were the result of negligence,21 while others were the result of failure to hire or assign appropriate staff.22 Other inappropriate procurement actions documented in the audit reports were intentional, such as splitting high value contracts into separate, lower value, contracts so as to avoid competition and review requirements.23 The picture which emerges, however, is a lack of respect for the procurement system, which has manifested itself by failure of the District to implement and fund procurement infrastructure and by agencies ignoring regulations and policy without consequence. Such neglect is pervasive in both major and minor ways.
The task force found that there are large variations in the training of procurement personnel between agencies, ranging from trained and experienced personnel to employees lacking either training or experience. This is particularly true in acquisition planning activities which are the responsibility of operating agencies. It is axiomatic that if planning is not timely done to allow sufficient time to undertake the procurement, no procurement system is likely to be successful.
The Task Force found that procurement regulations and procedures are difficult to access by both government agencies and the contracting public. The official compilation of Procurement Regulations published by the Office of Documents, Title 27 of the District of Columbia Municipal Regulations (“DCMR”), has not been updated since 1988, a period of over 18 years. Title 27 has not been included as one of the 12 DCMR titles currently available electronically. Not only has a current compilation of procurement regulations not been published, the list of amendments since the 1988 publication shown on the Office of Secretary website is only “current as of December 1999.”24 The problem is compounded by the adoption of separate procurement regulations by individual agencies25 pursuant to exemptions of certain agencies from all or part of the PPA and implementing Procurement Regulations.26 The exemptions themselves are not consistent. Some of the exemptions are total,27 while other are limited to specified contract actions,28 and still others grant specified agencies independent power to “exercise procurement authority to carry out [their] purposes, including contracting and contract oversight, consistent with the other provisions of this unit.”29
As important as regulations are, standard procurement forms and procedures which implement the regulations should also be readily available. Standard operating procedures are even less easily obtained than regulations. Although the OCP website now makes procedures adopted in the last 5 years available,30 that is not the case for most longer-standing procedures. The OCP website states, “Policies and procedures adopted prior to November 1, 2001 may be obtained by submitting a written Freedom of Information Act (FOIA) request to OCP's FOIA Office.” While many procedures have been formalized by the CPO in the past 5 years, it is incomprehensible that any standard operating procedures, regardless of age, are not immediately available without formality. The “system of unified and simplified procurement procedures”31 required by the PPA has not been developed. The Material Management Manual, the last comprehensive procurement manual, is over 30 years old and generally unavailable.
Other important publication and notice requirements are more honored in their breach than in their observance, further diminishing the respect for compliance with basic tenants of government procurement. Clear lines of contracting authority are basic to government procurement systems. By statute, contracting authority resides in the Chief Procurement Officer who may delegate the authority to other District employees. Delegations of procurement authority are required to be published “in the D.C. Register in January and July of each year.”32 As opposed to the definite requirements of the statute, publication is erratic, making notice difficult to locate. The last publication, as of August 9, 2006, was published in the September 15, 2006, DC Register.33
The establishment of the Chief Procurement Officer and the Office of Contracting and Procurement in 1997 was intended to raise the status of procurement within the District. Under the original law, the Chief Procurement Officer was required to "have not less than 7 years of procurement experience in federal, state, or local procurement, and shall have demonstrated management skills." In 1999, the Council increased the qualification standard by requiring senior-level procurement experience. Additional legislation amended the statute to provide that “[t]he CPO shall have not less than 7 years of senior-level experience in procurement and shall have demonstrated, through his or her knowledge and experience, the ability to administer a public procurement system of the size and complexity of the program established by this chapter.” [emphasis supplied] D.C. Official Code § 2-301.05e(d) as amended by D.C. Law 13-49.
Failure to appoint a CPO meeting the statutory qualifications has diminished the status and resulting authority of the office. For the past two years, the Office of Contracting and Procurement has been without a qualified, permanent, or even full-time, Chief Procurement Officer. The Interim CPO had impressive management credentials, but, by his own admission, had little procurement experience, let alone senior-level procurement experience. Further, the incumbent was only a part-time CPO. His responsibilities as Interim CPO were in addition to his responsibilities as the Deputy Mayor for Operations. The clear lack of priority in filling the position of Chief Procurement Officer decreased the office’s effectiveness and created the unfortunate appearance that compliance with procurement policy is not a high priority.
Although the position of Chief Procurement Officer is established by statute, it is within the prerogative of the Mayor to place the office within the organizational structure of the District. The CPO is in the third rank of District entities, not reporting directly to the Mayor, or even the City Administrator, but rather reporting through the Deputy Mayor for Operations, who in turn reports to the City Administrator, who reports to the Mayor.34 This is in contrast to the Attorney General and the Chief Financial Officer, who are at an organizational level equal to that of the City Administrator and report directly to the Mayor, and the Chief Technology Officer, who also does not report through a Deputy Mayor. The subordinate level of the Office of the Chief Procurement Officer certainly does not increase its influence with District departments.
Our review confirmed that authority and competition requirements which are supervised by the CPO are regularly ignored by operating departments without apparent sanction. Our review showed that unless there is a demonstrated will to comply with procurement policy, regulations, no matter how direct and clearly written, will be of little effect. In August of this year, the Inspector General issued a report which demonstrates the lack of will to control procurement activities within the government.35
In the late 1990s, the Council adopted crystal clear legislation dealing with the penalties for entering into any (a) verbal contract, or (b) multiyear contract or proposed contract over $1,000,000 without prior approval by the Council. DC Official Code § 2-301.05 states, in relevant part:
DC Official Code § 2-301.05a states, in relevant part:
Notwithstanding the clear requirements set by the Council, the number and dollar value of unauthorized contracts ballooned in both numbers and dollar value during the tenure of the Interim Chief Procurement Officer. The Inspector General reported that the number of contracts for which ratification of improper actions was required increased threefold from 19 in FY 2004 to 59 in FY 2005.36 Two agencies, the Department of Health and the State Education Office accounted for nearly half of the total number of improper contracts in FY 2005.37 The dollar value of improper contracts increased from $896,183 to $34,332,433, with the bulk of this amount being $33,009,214 for the Office of the Chief Technology Officer in just 6 contracts. It is difficult to believe that OCTO personnel dealing with contracts averaging over $5,000,000 each could not have been aware of the statutory requirements. It is not surprising that agencies have little regard for procurement requirements, since their violation is not treated seriously, even by the Office of Contracting and Procurement. Although the Council legislation specifically requires that “[t]he Mayor shall submit a report to the Council at least 4 times a year on the number of persons cited or terminated [for making an oral agreement],38 neither the CPO nor the agencies transmitted the information necessary to make such reports for FY 2004 or FY 2005 until after the issue was raised by the Inspector General in August.
The responses of the Interim CPO and agencies to the Inspector General’s findings highlight the fragmentation which makes it difficult to enforce responsibility for complying with procurement requirements. The CPO noted that he lacked responsibility for penalizing agencies or employees who make unauthorized commitments stating instead that penalties “should be enforced by those persons [within the agency] supervising the employees who enter into unauthorized commitments.”39
By its lack of authority to enforce procurement requirements within agencies, the OCP is isolated from agency actions critical to procurement. The OCP also lacks responsibility for payment on contracts. OCP asserted to the IG that “[i]t is not the Office of Contracting and Procurement’s responsibility to make payments or to follow up on a payment that should have been made; that is the function of the Chief Financial Officer.”40 Nevertheless, even without specific authority, the CPO has failed to use his “bully pulpit” to induce compliance.
The OCP has limited its role to processing procurement requests made by agencies. By doing so, it deprives the acquisition functions of critical expertise in the planning and timing of procurements, often impacting the time available for achieving maximum competition for the District’s needs.
If the OCP does not assume responsibility for agency actions at the beginning of the contracting process, or payment at its conclusion, it is impossible to hold anyone responsible for procurement deficiencies. In order to assume responsibility for procurement from beginning to end, OCP must have access to tools necessary to track all aspects of procurement. The District’s failure to give procurement the highest budgetary priority has kept such systems from being implemented.41 In 2003, the District began installation of the Procurement Automated Support System (“PASS”) intended to support the procurement system. The PASS system was designed to include 4 modules: contracting, sourcing, buyer and analysis. To date, only the buyer and analysis modules have been brought on line. The two active PASS modules are a financial recording system not designed as a procurement system and, while the installed modules may accurately record actions which are manually inputted to the system, the installed system offers no automatic preparation of documents, cues for necessary actions or controls for accuracy. The August report of the Inspector General indicated that a conflict between OCP and the Chief Technology Officer as to which office should fund the additional $2 million cost of installing the remaining PASS modules has delayed their installation.42 Lack of the full PASS system limits the system’s usefulness as a planning tool to monitor contracts as they approach maximum value and expiration date.
Based on these and other failures reviewed under our legislative mandate, the Task Force concludes that the problems in the procurement system are not as much in its laws, regulations and implementing procedures, as in the commitment of the government to follow them.
It would be easy to recommend that each department head be made accountable for his or her department’s procurement functions and be evaluated on success. Such a recommendation is unlikely to improve contracting. The primary goal of an agency head will always be success in the substantive function of the agency. A mayor will also, as a matter of course, give priority to meeting the substantive goals of his or her administration. It is therefore difficult to meaningfully sanction an agency head who excels at substantive goals, but is deficient in administrative matters. The lack of sanction of the Chief Technology Officer notwithstanding over $30 million of unauthorized contracts bears this out.
Without a reliable system of sanctions, then, the procurement process must be strengthened from within. Improvements are more likely to be achieved if the status, authority and scope of the Chief Procurement Office is enhanced and priority is given to fully supporting the acquisition system. The CPO must be granted authority to supervise the Office of Contracting and Procurement and agency employees with acquisition authority from planning for acquisitions through payment for completed contracts. With the change in administration and the vacancy in the office of Chief Procurement Officer, the District has the opportunity to quickly enhance the acquisition system within a short period of time.
We recommend that within the first 100 days of the new administration:
We recommend that within one year the new administration:43
We recommend that within one year the Council and the new administration:
We recommend that beginning with the Fiscal Year 2008 budget:
We recommend that beginning with the submission of the Fiscal Year 2009 budget (January 2008):
We recommend that beginning with the submission of the Fiscal Year 2010 budget (January 2009):
CONTRACTING AND PROCUREMENT TASK FORCE
Matthew Watson, Chair
D. C. CONTRACTING AND PROCUREMENT REFORM TASK FORCE
Matthew Watson, Chair, Contract Appeals Board (ret.), Former District of Columbia
EXECUTIVE BRANCH DESIGNEES
Elliott Branch, Executive Director for Contracts, Naval Sea Systems
Command. Former Chief Procurement Officer
Keith Coleman, Reed Smith LLP; District of Columbia Bar, Gov. Contracts & Litigation Section
1. Contracting and Procurement Reform Task Force Establishment Emergency Act of 2005
2. A list of members of the Task Force is attached.
3. Procurement Practices Act of 1985 (“PPA”). Chapter 3 of Title 2 of the D.C. Official Code (2001 ed.), (§ § 2-301.01 to 2-327.03)
4. § 2-301.07(37)
5. § 2-301.07(1)
6. 48 CFR § 2.101
7. Reorganization Plan No. 3 of 1967
8. Pub. L. 93-198, 87 Stat. 777 (Dec. 24, 1973)
9. Title 27, District of Columbia Municipal Regulations (DCMR)
10. Procurement Reform Amendment Act of 1996, D.C. Law 11-259, 44 D.C. Reg. 1423 (Mar. 14, 1997). The amendments did not, however, comprehensively amend the PPA to reflect the changed procurement organizational structure. For example, a number of unamended PPA provisions still place requirements on the “Director” which continues to be defined as “the Director of the Department of Administrative Services, established by Mayor's Order 84-52, dated March 2, 1984” (DC Official Code § 2-301.07(22)), a position which no longer exists. (See also, MCI Constructors, Inc., CAB No. D-1056, Mar. 27, 2002, 50 DC Reg. 7412, 7417). 11 2000 Model Procurement Code for State and Local Governments (ABA Section of Public Contract Law 2006 ed.)
12. We should note, however, that the badly outdated District procurement regulations – which have not been substantially revised since the 1980s – are nevertheless a drag on efficiency in the District’s procurement system. To the extent the District’s procurement rules are badly out of step with the federal regulatory regime, federal contractors – and, more importantly, highly capable federal contracting officials – will be reluctant to “cross over” to participate in the District’s procurement process. In essence, an antiquated regulatory system helps make the District an island in the surrounding region’s burgeoning sea of resources for effective procurement.
13. DC Auditor report entitled “Evaluation of the Department of Public Works’ Monitoring and Oversight of the Ticket Processing and Delinquent Ticket Debt Collection Contracts (April 22, 1999) – Award of four 45-day-or-less sole source emergency contracts and one one-year sole source contract due to failure to plan in advance and other administrative delays.
14. Inspector General report entitled “Audit of the District of Columbia Public Schools’ Procurement of School Security Services” (OIG No. 03-2-14GA) (April 26, 2004) - Extension of the original contract for two additional years without soliciting and receiving the benefits of price competition.
15. DC Auditor report entitled “District of Columbia General Hospital’s Sole Source Contract Award to Medical Services Group, Inc. Violated D.C. Laws and Regulations’ (July 14, 1997) –sole source contract awarded to retiring employees of the agency.
16. DC Auditor report entitled “Current Status of the Contract for the District’s Consolidated Real Property Inventory System” (July 27, 2000) – Task order totaling over $500,000 entered into by Deputy Mayor with delegated contracting authority not to exceed $25,000.
17. Inspector General report entitled “Audit of Contracting Actions for the District’s Administrative Services Modernization Program (OIG 04-1-12MA) (May 3, 2005) - Of the 31 labor hour contracts reviewed, none were assigned a Contracting Officer’s Technical Representative (“COTR”) or contract administrator.
18. Inspector General report entitled “Audit of the District of Columbia Housing Authority’s Financial Management of Hope VI Grant Funds” (OIG 01-2-25PH(c)) (Sept. 9, 2003) – Agency did not maintain sufficient records for 45 percent of the payments it made to contractors.
19. Inspector General report entitled “Audit of Procurement Activities at the D.C. Fire and Emergency Medical Services Department” (OIG No. 02-1003MA) (May 4, 2004) - Contracting officials did not adequately document procurement files to demonstrate that goods/services were delivered, and to record and verify that payments were made.
20. DC Auditor report entitled “District of Columbia Sports and Entertainment Commission’s Contracting, Procurement, and Spending Practices Characterized by Mismanagement, Noncompliance, and Inadequate Internal Controls” (October 17, 2003) recommended that the Sports Commission, which is not subject to the PPA, develop a comprehensive set of procurement regulations, policies and procedures in order to establish a basis for purchasing that is transparent and responsible.
DC Auditor report entitled “Agency Retaliation against Contractors Appearing Before or Providing Information to the Council (April 12, 2000) recommended that the the “Employees of District Contractors and Instrumentality Whistleblower Protection Act of 1998” (D.C. Law 12160) be expanded clearly prohibit retaliatory actions against contractors, in addition to individual employees.
Inspector General Inspection Report on the Office of Contracts and Procurement issued August 23, 2006, after the formation of the Task Force recommended that language be clarified in the regulations dealing with bid submission (27 DCMR § 1504) to allow submission of bids electronically.
21. Inspector General Report entitled “Audit of the District of Columbia Housing Authority’s Financial Management of Hope VI Grant Funds” (OIG 01-2-25PH(c)) (Sept. 9, 2003) - DCHA also did not maintain sufficient records for 45 percent of the payments it made to contractors. 22 Inspector General Report entitled “Audit of the Health Care Safety Net Contract,” (OIG 02-12HC) (Oct. 4, 2002) - failure to fill oversight positions at HCSNA in a timely manner.
Inspector General Report entitled “Audit of Contracting Actions for the District’s Administrative Services Modernization Program” (OIG 04-1-12MA) (May 3, 2005) - Of the 31 labor hour contracts reviewed, none were assigned a COTR or contract administrator.
23. Inspector General Report entitled “Audit of Procurement Activities by the Office of Contracting and Procurement for the Department of Consumer and Regulatory Affairs” (OIG 021-3MA (a)) (Aug. 27, 2003) - Of the 46 $25,000 contracts awarded for nuisance abatement services, 42 were awarded to 12 contractors. All twelve contractors received awards for improperly split contracts which otherwise would have been over the $25,000 threshold. As a result, contracting officers did not make responsibility determinations.
24. The last amendment listed on the website is actually June 2, 2000. Later amendments to Title 27 are included in monthly “List[s] of Sections Amended” published in the D.C. Register, now apparently published quarterly. Amendments to Title 27 promulgated by the OCP are listed on the OCP website. A compilation of the section containing the current Contract Appeals Board (“CAB”) rules is published on the CAB website (www.cab.dc.gov).
25. See, e.g., 19 DCMR Chapter 28, which states in its first section:
The differences may set traps for unsuspecting contractors. For instance, under the PPA, a prospective contractor may, in general, file a protest within “10 business after the basis of protest is known.” (DC Official Code § 2-308.08(b)). A prospective contractor aggrieved by a Sports Commission decision loses its right to protest if the protest is not filed “within 7 days….” 19 DCMR 2808.1.
26. DC Official Code § 2-303.20
27. See, e.g., DC Official Code § 2-303.20(j) (Water and Sewer Authority)
28. DC Official Code § 2-303.20(i) (procurements under $500,000 by the Metropolitan Police Department)
29. See, e.g., DC Official Code § 2-303.20(p) (Department of Mental Health)
31. DC Official Code § 2-302.02(b)
32. DC Official Code §§ 2-301.05(a) and (c)3
33. 53 DC Reg. 2557-72
35. Office of Contracting and Procurement, Part One, Report of Inspection (OIG-No, 06-001770) (August 23, 2006) (“OIG Report”)
36. At 18
37. At 20
38. 2 DC Official Code § 301.05(d)(3)
39. OIG Report, at 21
40. At 24
41. By statute, the Material Management Information System should have been completed nearly 10 years ago. DC Official Code § 2-302.02(c)(1) provides:
42. OIG Report, at 37-8
43. The Task Force recognizes that funds will be required to be reapportioned and made available to the OCP during FY 2007 to the extent that these recommendations are implemented prior to September 30, 2007. The Task Force estimates increased costs of $3 to $6 million during FY 2007 to begin implementation.
44. Based on FY 2006 expenditures, the Task Force estimated the amount available for contracting to be $3.75 billion.
45. This sum includes appropriations of District funds, Federal payment and grant fund, property sales and private grants and donations.
46. In February of this year, the Council passed a similar reporting requirement for contracts over $1 million. (D.C. Law 16-122, § 2(f), 53 DCR 2834 (June 6, 2006), codified in relevant part as DC Official Code § 2-303.19a). While this legislation is worthwhile, the reporting date, on month into the fiscal year, is not sufficient to assure adequate time for competition and award. Further, the new report is limited to plans for resolicitation of needs for which contracts are expiring and does not require reporting plans for newly budgeted contract programs. The Task Force has therefore recommended, in addition to reporting new contracts and a lower dollar threshold, that the report be filed with the submission of the budget, giving at least a 6 month additional lead time.
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