2017-014(F) Supporting Statement Part A 5.30.23

Federal Acquisition Regulation (FAR)

Acquisition 360 Voluntary Survey

OMB Control No. 9000-XXXX

Justification – Part A Supporting Statement

FAR section affected: 52.201-XX

Overview of Information Collection:

• This justification supports clearance of a new collection related to FAR Case 2017-014, Use of Acquisition 360 to Encourage Vendor Feedback.

• This information collection is needed for the Acquisition 360 Survey which is a voluntary customer satisfaction survey used to seek information from actual and potential offerors regarding their experience with Federal contract solicitations.

• The Acquisition 360 Survey is available at https://www.acquisition.gov/360.

• This information collection is a common form. The General Services Administration (GSA) is the sponsor agency of this common form. All executive agencies covered by the FAR will use this common form, and report their agency burden separately.

1. Need & Method for the Information Collection. This information collection covers the Acquisition 360 Survey tool which seeks information from actual and potential offerors regarding their experience with Federal contract solicitations. Understanding how offerors experience the Federal marketplace is critical to the Government’s ability to build and maintain a healthy, diverse, and resilient supplier base that can help Federal agencies use acquisition as a catalyst to address the needs of our Nation. While agencies periodically seek feedback from their offerors, there are no government-wide mechanisms for agencies to collect and consider this information in a consistent and organized manner. The Acquisition 360 Survey fills an important gap in government-vendor communications by providing a standardized tool for voluntary vendor feedback in a centralized location to allow for cross agency analysis.

In 2015, the Office of Federal Procurement Policy (OFPP) conducted a pilot of the Acquisition 360 Survey as established by the memorandum "Acquisition 360-Improving the Acquisition Process through Timely Feedback from External and Internal Stakeholders¹.” In 2019, OFPP issued “Myth-Busting #4 – Strengthening Engagement with Industry Partners through Innovative Business Practices²” which supported expanded use of the Acquisition 360 Survey.

The Office of Management and Budget (OMB) hosts the centralized survey portal at https://www.acquisition.gov/360 to ensure governmentwide access to the data. The voluntary survey will be available at the public website where respondents will enter the Notice ID/Solicitation ID of the solicitation they wish to comment on, and then select their role in the procurement— Actual/Potential Offerors, Government Contracting Office, or Government Program Office (Customer). Based on the role selected, the respondent will be presented with a set of standardized survey questions. Only the Actual/Potential Offerors portion is for public use and therefore, the only portion of the survey covered by this information collection. The survey responses will be overseen by the OMB project team (which is comprised of members of OFPP and the General Services Administration (GSA) Office of Shared Solutions & Performance Improvement).

Research Test and Questions

1. What are the current pain points experienced by contractors, contracting offices, and government program offices during the preaward (plus debrief) phase of the acquisition lifecycle?

2. How do the pain points differ across spend categories (e.g., IT) and socio-economic small business categories (small disadvantaged businesses, women-owned small businesses, etc.)?

3. How do changes in training, guidance, and outreach efforts improve vendor satisfaction levels through survey responses year over year?

This clearance covers the information that actual and potential offerors may submit in

accordance with the following Federal Acquisition Regulation (FAR) requirement as stipulated in agency procedures:

FAR 52.201-XX, Acquisition 360: Voluntary Survey. This provision encourages actual and potential offerors to provide feedback to agencies on their preaward and debriefing process using a Government-provided survey at https://www.acquisition.gov/360. (See the survey questions Attachment.)

2. Use of the Information. The purpose of the Acquisition 360 Survey is to standardize the gathering of feedback regarding preaward and debriefing actions so that agencies can continually consider and improve their performance in early vendor engagement efforts and internal acquisition practices. Standardized feedback will provide more meaningful insight on ways to strengthen the contracting process than feedback derived from ad hoc or periodic agency satisfaction surveys. Offerors invest considerable time and money in responding to government requests for proposals (RFPs), and ambiguous requirements, unnecessarily complex solicitations, and other process challenges can greatly increase the burden on offerors and the cost to the government.

The responses to the surveys are intended to be used by agency Chief Acquisition Officers, Senior Procurement Executives, vendor engagement officials, and other appropriate agency leaders to strengthen their agency acquisition practices. Additionally, the OMB project team will link the Notice ID/Solicitation ID provided from all survey responses to the associated Federal Procurement Data System (FPDS) Contract Action Records (CAR) to provide numerous data points on the procurements including contracting office, amount, product/service acquired, and contract type. The resulting information can assist OFPP and the agencies in identifying trends and areas to expand guidance, education, and outreach efforts.

Additionally, the responses to the voluntary survey by small businesses may provide insights into the difficulties faced by small disadvantaged businesses in the preaward phase of the acquisition lifecycle. OFPP and agencies can use this information to support efforts to increase the share of awarded contracts to small disadvantaged businesses.

Terms of clearance for use of the information if it is publicized: Before public release of any of the data associated with this collection, the OMB project team will submit the materials for the OMB Office of Information and Regulatory Affairs’ review.

 

3. Use of Information Technology. Federal agencies use information technology to the maximum extent practicable. The voluntary survey responses will be captured via the centralized survey portal at https://www.acquisition.gov/360.

Efforts have been made to reduce the burden of the Acquisition 360 Survey throughout its development. Earlier iterations of the survey required respondents to enter three pieces of identifiable information: contract identifier, Product Service Code, and Activity Address Code. Going forward, only the Notice ID/Solicitation ID will be required; the Product Service Code and Activity Address Code will be linked via publicly available information in the FPDS CAR. Additionally, the question set provided to the respondent is based on the role selected (waterfall approach); removing the need for users to view irrelevant questions. Additionally, there is an option for “Not Applicable” for each question, so respondents are not obligated to respond to questions that are irrelevant to their experience. While the survey is designed to only require one offeror response per solicitation, offerors may take the survey for as many solicitations as they choose. The survey responses will utilize the Qualtrics application, and the data will be stored on a SQL server within the Data to Decisions (D2D) platform at the General Services Administration.

4. Non-duplication. These requirements are issued under the FAR, which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication. While agencies periodically seek feedback from actual or potential offerors, there are no government-wide mechanisms for agencies to collect and consider this information in a consistent and organized manner. The differing content and frequency of agency satisfaction surveys make cross agency analysis of the responses limited in their utility. The Acquisition 360 Survey fills an important gap in government-vendor communications by providing a standardized tool for voluntary vendor feedback that allows for cross agency analysis.

5. Burden on Small Business. The burden applied to small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices. The survey is voluntary, anonymous and will not impact source selection decisions.

6. Less Frequent Collection. If the Acquisition 360 Survey is not conducted or conducted less frequently, agencies would continue to elicit feedback using various other methods, however, these other methods would not accomplish the standardization objectives of the Acquisition 360 Survey or allow for cross agency analysis.

7. Paperwork Reduction Act Guidelines. Collection is consistent with guidelines in 5 CFR 1320.5(d)(2). The Acquisition 360 Survey results are not intended to be generalizable to all actual and potential offerors, but used to gain insight into experiences when competing for government contracts or to identify areas where further research or analysis is needed.

8. Consultation and Public Comments.

1. An advance notice of proposed rulemaking (ANPRM) was published in the Federal Register at 83 FR 34820 on July 23, 2018, to obtain public input regarding matters related to contractor feedback, the overall cost of compliance, and any specific regulatory requirements that are particularly burdensome. The initial Acquisition 360 Survey questions were posted as part of the ANPRM.

2. A 60-day notice was published as a part of the notice of the proposed rulemaking for FAR case 2017-014 in the Federal Register at 85 FR 57177, on August 15, 2020. A respondent provided comments on a variety of issues on the proposed rule; one of the comments expressed support for this collection of information.

Comment: Regarding whether the collection of information will have practical utility, the commenter stated that if better communication aids in the proper performance of FAR functions, both the information and the initiative to promote voluntary feedback has merit. The commenter finds this collection to be a worthy time investment to facilitate effective communication that could prevent delays or errors due to miscommunication.

Response: Noted.

3. A 30-day notice was published in the Federal Register at XX FR XXX, on XXX.

9. Gifts or Payment. This collection does not provide any payment or gift to respondents.

10. Privacy & Confidentiality. The information collected through the Acquisition 360 Survey is disclosed only to the extent consistent with prudent business practices, current regulations, and statutory requirements.

The Acquisition 360 Survey does not request any personally identifiable information and asks respondents to refrain from entering any information which could identify themselves or any other individuals in the open response fields. There will be no effort to identify responses to specific entities. No proprietary information is necessary to respond to the survey questions. The survey responses will have a delayed posting to minimize the risk of the responses influencing ongoing procurements.

Privacy

The Acquisition 360 Survey is subject to the Privacy Act of 1974. System of Records Notices (SORNs) and Privacy Impact Assessments currently cover the data linked to survey responses:

• Federal Procurement Data System—Next Generation (FPDS-NG)

  • SORN ID: GSA/OAP-3

  • Privacy Impact Assessment (PIA) dated 20 July 2020, https://www.gsa.gov/cdnstatic/Federal%20Procurement%20Data%20System%20-%20Next%20Generation%20(FPDS-NG)_PIA_July2020docx.pdf

• System for Award Management (SAM.gov)

  • SORN ID: GSA/GOVT-9

  • Privacy Impact Assessment (PIA) dated 16 July 2020, https://www.gsa.gov/cdnstatic/System_for_Award_Management_(SAM)_PIA_July2020docx.pdf

Assurance of Privacy

There is no assurance of privacy or confidentiality, the survey asks that respondents refrain from entering any information which could identify themselves or any other individuals in the open response fields to help maintain anonymity. No virtual tokens are used to invite or document respondents.

Data Security and Monitoring

The Acquisition 360 Survey data will be monitored for the number of responses to related procurements and saboteurs/bad actors—none of which were encountered during the previous iterations of the survey. Decisions around improving policy implementation and training will be made based on the identification of trends that are fully investigated and researched. The system portal where the responses to the survey will be held, has a plan and processes for data security.

Data Access Plans

There is no plan to publicize raw data from the Acquisition 360 Survey. The intention is to publicize efforts taken in response to the survey data so that all parties can understand the impact and efforts undertaken as a result. For example, in previous efforts OMB issued a memorandum³ focused on improving debriefings based on feedback received through survey responses that pointed to debriefings as one of the most valuable events during the acquisition lifecycle. Internally, data is shared with agency Chief Acquisition Officers and Senior Procurement Executives to assist in directing their agencies’ efforts to strengthen their agency acquisition practices.

Data will be collected in a de-identified format and it will not include any direct identifiers (unless inadvertently input by respondent in the open response section). Data from the survey will be transferred to, stored, and analyzed on a secure server in limited-access project folders to which only members of the project team have access.

11. Sensitive Questions. There is no request for sensitive information (information that is commonly considered private, including bio-specimens).

12. Burden Estimate.

Estimated total annual public hour and cost burden.

When included in a solicitation, the provision encourages offerors to respond electronically to a standard question set. Agencies are not required to include the survey in solicitations, but when it is included, offerors are not required to respond to the survey as participation is voluntary. The voluntary nature of the implementation requires the use of various assumptions, to include those based on the results of the original pilot.

Data obtained from the FPDS for Fiscal Years (FY) 2020, 2021, and 2022 indicates that GSA awarded an average of 54,328 contract actions. The pilot required agencies to place the survey in 50 contracts or 5% of new contract actions. For this estimate, it is assumed that agencies may include FAR 52.201-XX in 5% of new contract actions, meaning that 2,716 (54,328 x 5%) contract actions would be impacted. It is also assumed that three offers will be received for each new contract action, resulting in an estimated 8,148 actual and potential offerors. The Government anticipates a 33% response rate, or 2,689 responses based on data obtained through the OFPP pilot. We estimate the survey will take 10 minutes to complete. We also estimated that the responses per respondent would be one.

General Services Administration

Estimated number of respondents/yr................2,689

Responses per respondent..............................  x 1

Total annual responses.................................. 2,689

Estimated hrs/response................................ x .1667

Estimated annual burden hours....................... 448

Hourly rate.................................................. x $54*

Estimated annual cost to the public........... $24,192

* Based on the Office of Personnel Management (OPM) 2023 General Schedule (GS) 9/step 9 salary for the rest of the United States ($34.67 per hour) plus a 36.25 percent fringe factor, rounded to the nearest whole dollar ($48). The fringe factor used is pursuant to the rate provided in OMB memorandum M-08-13 for use in public-private competition. Plus, a 12% overhead rate (from A-76 revised supplemental handbook) additional to the fringe factor rate, rounded to the nearest dollar ($54).

13. Estimated nonrecurring costs. Not applicable.

14. Estimated cost to the Government.

It is estimated that one half hour is required for the Government to review and analyze each response received from the Acquisition 360 Survey.

General Services Administration

Estimated responses/yr................................... 2,689

Reviewing time (hr)/response........................  x .5

Review time /yr.............................................. 1,345 (rounded up to nearest whole number)

Hourly rate................................................. x $54*

Estimated annual cost to the Government… $72,630

15. Reasons for changes. None, this is a new information collection.

16. Publicizing Results. The Acquisition 360 Survey will be ongoing and available for receiving standardized feedback from actual and potential offerors regarding Federal contract solicitations. The survey response data will be shared with agencies via access-controlled websites such as OMB Max. The OMB project team intends to publicize efforts taken in response to the survey data so that all parties can understand the impact and efforts undertaken as a result of the survey responses.

17. OMB Not to Display Approval. Approval to not display the expiration date for OMB approval of the information collection is not sought.

18. Exceptions to "Certification for Paperwork Reduction Submissions. There is no exception to the certification statement.

Attachment

Acquisition 360 Survey

FPDS data for GSA
FY	No of contracts
2020	54551
2021	55474
2022	52960
Avg	54328

1 https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/procurement/memo/acquisition-360-improving-acquisition-process-timely-feedback-external-internal-stakeholders.pdf

2 https://www.whitehouse.gov/wp-content/uploads/2019/05/SIGNED-Myth-Busting-4-Strenthening-Engagement-with-Industry-Partners-through-Innovative-Business-Practices.pdf

3 https://www.whitehouse.gov/wp-content/uploads/legacy_drupal_files/omb/procurement/memo/myth-busting_3_further_improving_industry_communications_with_effectiv....pdf