Department of the Interior
Departmental Manual
Effective Date: 6/16/87
Series: Personal Property and Services
Part 405: Business and Economic Development Program
Chapter 1: Management Review
Originating Office: Office of Small and Disadvantaged Business Utilization
405 DM 1
1.1 Purpose. This chapter establishes uniform policies and procedures to conduct Business and Economic Development Program Management Reviews. These reviews are necessary to effectively evaluate implementation of Interior’s Small and Disadvantaged Business Program (E.O. 11625), the Labor Surplus Area Concern Program (P.L. 95-89 and E.O. 12073), the Women’s Business Enterprise Program (E.O. 12138) and Public Law 95-507. They also provide oversight of the bureaus= and offices= responsibilities in carrying out the duties relating to Sections 8 and 15 of the Small Business Act, as amended.
1.2 Responsibilities.
A. The Office of Small and Disadvantaged Business Utilization (OSDBU) is responsible for:
(1) Administering and coordinating OSDBU Business and Economic Development Program Management Reviews, providing program policy direction, guidance and the resources necessary to carry out the program.
(2) Developing, organizing and providing technical guidance for this program.
(3) Selecting the bureaus and offices where Business and Economic Development Program Management Reviews will be conducted and scheduling and coordinating the reviews. Business and Economic Development Program Management Reviews will be coordinated with the Division of Acquisition and Grants (DAG) to avoid conflicts between Procurement Management Reviews conducted by the Office of Acquisition and Property Management (PAM).
(4) Selecting and designating OSDBU personnel to make the Business and Economic Development Program Management Review. Personnel conducting the review will prepare for it by reviewing previous staff review reports, correspondence, management data, Inspector General and audit reports.
(5) Budgeting for OSDBU Business and Economic Development Program Management Reviews.
(6) Preparing and distributing required reports and conducting entrance and exit interviews with the head of the procuring activity or other appropriate officials at the bureau or office.
(7) Receiving, reviewing and making recommendations for program improvements to the bureau or office.
B. Bureaus and offices are responsible for:
(1) Orienting the OSDBU staff personnel conducting a Business and Economic Development Program Management Review and furnishing necessary office space and professional and clerical assistance.
(2) Making available contract files and records to be reviewed during the Business and Economic Development Program Management Review.
(3) Making arrangements for an entrance and exit interview at the beginning and conclusion of the Business and Economic Development Program Management Review.
(4) Establishing a program to make Business and Economic Development Program Management Reviews of subordinate activities that have assigned Business Utilization and Development Specialists (BUDS) no less than once every 24 months.
(5) Budgeting for Business and Economic Development Program Management Reviews of subordinate activities.
(6) Preparing and distributing required reports and conducting entrance and exit interviews with the head of the procuring activity or other appropriate officials at subordinate activities.
(7) Receiving, reviewing and making recommendations for program improvements to OSDBU.
(8) Implementing the recommendations contained in the Business and Economic Development Program Management Review Report. Narrative status reports on the progress made in implementing the recommendations will be prepared biannually, based on the date of the report, and submitted to OSDBU for review. Reporting is required until all recommendations are implemented or cancelled by OSDBU.
1.3 Procedures.
A. Review Schedule.
(1) The OSDBU planned review and its scheduling will be discussed informally with the appropriate bureau official and/or BUDS, with the procuring activity, and confirmed in writing to the Director of the bureau at least four weeks in advance of the review.
(2) Reviews of field offices with minor procurement responsibilities within the bureaus will normally be arranged for and conducted by the bureau BUDS. However, there may be occasions when the OSDBU staff may determine to include a review of field office(s) with minor procurement responsibilities in its itinerary. In such cases, the planned schedule will be coordinated with the BUDS at the bureau to avoid interference with the bureau’s Business and Economic Development Program Management Reviews.
B. Conduct of Review.
(1) Upon arrival of the review team and during the entrance interview, the senior procurement official will be advised of the objectives of the review and program areas which will be given particular emphasis.
(2) Business and Economic Development Program Management Review reports by BUDS to subordinate activities which are related to the present review, will be reviewed to ascertain progress made with respect to previous recommendations. This should not be construed as relieving audit or other inspection activities of their responsibility for official follow-up.
(3) Program statistics and records should be sampled to determine problem areas requiring special attention. Reports will include comments pertaining to each program area and the effectiveness and contribution of each appropriate organizational element in accomplishing the overall bureau goals and objectives.
(4) The contracting procedures, files and end products will be examined as a means of determining the quality of the bureau/office program. Conclusions should not be made based on any one single indicator. Informal interviews with selected contracting personnel should be conducted. Interviews and observations, combined with review of contract files, provide the basis for determining the quality of the program. Any judgment made in this regard will be discussed with appropriate contracting personnel.
C. Contract and Purchase Order Sampling.
(1) Contracts and purchase orders are the mirror image of a contracting activity=s sensitivity and dedication toward the Business and Economic Development Program. Through careful selection of contracts and purchase orders to be reviewed, insight will be gained to reveal the pattern of the organization’s thinking in carrying out this important program.
(2) The first step in the sampling process is to determine and select for review an adequate representative sample which considers the nature of the contracts (i.e., research and development, supply, construction, small purchase etc); dollar value; number of contracts; and type of contract (i.e., fixed price, cost plus fixed fee, incentive, etc.). Contracts to be considered for selection are those placed during the last complete fiscal year, plus those placed in the current year to date.
(3) A contract and purchase order stratification should be prepared from information which is readily available to the activity which will conduct the review. It should identify contracts and purchase orders under $10,000; between $l0,000 and $100,000; between $100,000 and $1,000,000; and over $1,000,000 in value. Careful review of such stratification will assist in identifying contracts which are likely candidates for review by the nature of the contract, the dollar amount, the item or service being procured or any other circumstance which make it an appropriate candidate for inclusion under some phase of the Business and Economic Development Program. If problems are encountered in locally obtaining a stratification, the OSDBU Data Base Management Specialist, U.S. Department of the Interior, Room 2747, 18th & C Streets, N.W., Washington, D.C. 20240, on ETS 343-8494, shall be contacted for assistance.
(4) Another method of sampling which may be used in combination with the stratification mentioned above is random selection by review of the activities contract register.
(5) All negotiated contracts which have been awarded to large business firms and exceed $500,000, or $1,000,000 for construction, should be reviewed.
(6) Small purchases, if large in number, may be selected for review through application of random sampling techniques. Tables of random numbers may be found in the Code of Federal Regulations (CFR) Title 41, Chapter 18 National Aeronautics and Space Administration, Supplement No. 3, Subpart 7, Annex III.
D. Exit Interview. Observations, comments and recommendations, which are to be included in the report, will be discussed with the head of the procuring activity prior to departing.
E. Reports.
(1) A draft report (Report Control Symbol DOI-87-097) will be prepared by OSDBU or bureau BUDS within 45 workdays after completion of the review. The draft report will then be submitted to the bureau site for comment or concurrence. The report should not include items not previously discussed during the exit interview.
(2) A final report will be prepared by OSDBU or bureau BUDS within 45 workdays after receiving bureau site comments or concurrence. The comments or concurrence from the bureau site will be included in or attached to the final report.
F. Reporting Format.
(1) The report is to include, as a minimum, the following information:
(a) Location and dates of the review;
(b) Purpose of the review;
(c) Names, titles, telephone numbers of all individuals contacted during the review;
(d) An introduction which discusses the volume of the procurement activity at the site;
(e) The goals and accomplishments for the activity along with a trend analysis;
(f) A description of the types of products and services bought by the activity;
(g) Ranges of the average procurement over $10,000 and a description of the small purchase activity;
(h) A section listing all recommendations in numerical order;
(i) A section listing all of the attachments to the report if there are any; and
(j) Description of the exit interview.
(2) Each subject area reviewed should be discussed separately in the report and numbered consecutively. For each subject area there should be, as a minimum, the following parts:
(a) Findings;
(b) Problems or strengths; and
(c) Recommendations
(3) Examples of subject areas to be reviewed include but are not limited to:
(a) Procurement screening procedures;
(b) Advance procurement planning;
(c) 8(a) contracting procedures;
(d) Subcontracting plan procedures;
(e) Subcontracting plans and compliance;
(f) Reporting;
(g) Out-reach activities;
(h) Contract file documentation;
(i) Goaling process;
(j) Bidders mailing lists and other source lists;
(k) Utilization of BUDS;
(1) Small purchases;
(m) Involvement with the Small Business Administration; and
(n) Orientation and periodic training of activity personnel in national and Interior Small and Disadvantaged Business Utilization Program policy.
G. Distribution of Reports. After review by the Director, OSDBU, copies of the final report will be submitted to the bureau head; Inspector General=s office; and the Office of Acquisition and Property Management, Division of Acquisition and Grants in the Office of the Secretary.
H. Follow-up Procedures. To ensure implementation of recommendations considered serious in nature, a special follow-up visit to the bureau site may be required. The bureau site should be allowed sufficient time to initiate/complete the corrective action before the follow-up visit is made. Follow-up for observations considered minor in nature will be accomplished during the next Business and Economic Development Program Management Review visit, or by telephone or correspondence, as appropriate.
6/16/87 #2748
Replaces 11/2/83 #2535