On September 29, 2006, the OIG issued Management Advisory Report 6-33, Concerns Related to SBA’s Acquisition Personnel Education & Training. The objectives in conducting the survey were to determine the extent to which SBA implemented the Office of Federal Procurement Policy Letter 05-01, Developing and Managing the Acquisition Workforce. Policy Letter 05-01, issued by the Office of Management and Budget on April 15, 2005, incorporated Policy Letters 92-3 and 97-01, which established the government-wide framework for creating a Federal acquisition workforce. Policy Letter 05-01 aims to improve the development of the acquisition workforce by more broadly defining this workforce and by more closely aligning the education, training, and experience requirements between defense and civilian agencies for entry and advancement in the acquisition career fields. It also requires a certification program for acquisition personnel in civilian agencies. This survey focused on determining whether the SBA had (1) identified its acquisition workforce, (2) maintained information on the education and experience of acquisition staff, and (3) assessed the skill level of this workforce.
The OIG found that the SBA had not completed the basic steps necessary to comply with Policy Letter 05-01 including: (1) identifying its acquisition workforce; (2) collecting experiential and training information on its acquisition workforce; and (3) assessing the skill level of its workforce. Consequently, the SBA cannot provide assurances that it has a highly qualified and well-trained acquisition workforce that possesses the core competencies specified by OMB. Policy Letter 05-01 requires that agencies identify all individuals involved in acquisitions, including those working outside traditional contracting functions that are responsible for determining procurement requirements, measuring contract performance, and providing technical and management direction so they can be developed using common standards.
Additionally, OMB requires that at a minimum, agencies include all positions in the General Schedule contracting series (GS-1102); all Contracting Officers with the authority to obligate funds above the micro-purchase threshold regardless of general schedule series; program and project managers as identified by the agency’s CAO; all contracting officer’s representatives and contracting officer’s technical representatives; and any significant acquisition-related positions identified by the CAO using the guidance from Policy Letter 05-01. Further, the SBA has not collected or maintained individual education, training, and experience data on members of its acquisition workforce. According to OMB Policy Letter 05-01, each Federal agency have complete, current records in the Federal Acquisition Institute's Acquisition Career Management System (ACMIS) for, at a minimum: all positions in the general schedule contracting series (GS-1102); all contracting officers regardless of general schedule series with authority to obligate funds above the micro-purchase threshold; and all positions in the general schedule purchasing series (GS-1105).
The Clinger-Cohen Act, which amended the Office of Federal Procurement Policy Act pertaining to the Federal acquisition workforce, and Policy Letter 97-01, stipulated that Federal agencies should develop a management information system to track acquisition workforce continuing education requirements. The former AA for Administration told the OIG that such a system had not been developed. Once the SBA fully identifies its acquisition workforce, it will need to assess the skills of this workforce to identify short-term and long-term hiring and training needs, and establish plans, including recruitment and retention strategies, in order to obtain the acquisition workforce resources and skills required to meet future Agency mission needs. Without documented plans to fulfill the requirements of Policy Letter 05-01, which SBA has yet to develop, SBA risks not having a highly qualified, well-trained SOP workforce based on the framework of core competencies specified by OMB.