Centralized Professional Services System (CPSS) ePortal Assessment Framework

Background

In 2006, the Office of the Auditor General (OAG) identified a requirement (Management Action Plan) for the establishment of a process to monitor and control the use of the Professional Services (PS) Online System to ensure federal departments and agencies:

• Follow Treasury Board Contracting Policy;

• Do not use the procurement tool to circumvent Canada's obligations under the various trade agreements.

This requirement was met in 2008, with the implementation of an Assessment Framework [process] developed by the Online Services Division (OSD), Services and Technology Acquisitions Management Sector (STAMS), Acquisitions Branch, Public Works and Government Services Canada (PWGSC).

In 2009, the PSOnline Assessment Framework was used as a baseline to develop an Assessment Framework [process] for Temporary Help Services (THS) On-Line.

In 2010, the Office of Audit and Evaluation established a mandate "to allow PWGSC to discharge its responsibilities related to the monitoring of the usage of PWGSC procurement vehicles" and launched "a continuous review program to monitor the usage of contracts awarded by other government departments using these vehicles."

In 2011, in response to the mandate of the Office of Audit and Evaluation, a pilot assessment project for THS was completed, based on the Assessment Framework developed for THS On-Line in 2009. This work involved the Client Engagement Sector – Office of Small and Medium Enterprises - Strategic Engagement (OSME-SE) and the Online Services Division.

In 2011, the Office of the Procurement Ombudsman (OPO), completed a review of the PSOnline automated procurement tool, including the Assessment Framework [process] used to monitor and control the use of this self-serve procurement tool. A report was released re-affirming the need for and the benefits of an assessment process (a copy of the report can be viewed via the following website: Procurement Practice Reviews - Professional Services Online).

In April 2012, revisions to the PSOnline Assessment Framework [process] were made to respond to the OPO report and assessments of the PS Online automated procurement tool were carried out and completed in FY2012/13 (Fiscal Year).

In FY2013/14, further revisions were made to the Assessment Framework [process] for assessments completed on 3 departments using THS On-Line. These changes reflect the experience gained in carrying out the PSOnline assessments, as well as recommendations made by OPO.

Assessment Framework [process] - CPSS ePortal

Objective

To monitor and control the use of the self-serve procurement tools accessed through the CPSS ePortal.

Scope

In FY15/16, as part of the Professional Services National Procurement Strategy an Assessment Framework [process] will be implemented for the Methods of Supply (MoSs) in the CPSS ePortal.

The annual process is to involve the assessment of files (call-ups and contracts where applicable) from all Methods of Supply in the CPSS ePortal [Learning Services, Professional Audit Support Services (PASS), ProServices, Solutions Based Informatics Professional Services, Task Based Informatics Professional Services (TBIPS) and Task and Solutions Professional Services (TSPS – task and solutions)].

Documentation

Assessments will be based on the harmonized business rules for the Methods of Supply in the CPSS ePortal.

Guidance Document:

An Assessor Guidance Document will be created to provide specific such as a description of how assessment findings are to be established and the type of finding. Types of findings include:

• Major (Policy Related) Non-Conformance – Action taken (or lack thereof) by the Federal Department User that results in either a contravention of Treasury Board Contracting Policy or Federal/Provincial legislation.

• Major (Procedural Related) Non-Conformance - Action taken (or lack thereof) by the Federal Department User that results in, for example, the improper use of a MoS in the CPSS ePortal.

• Minor Non-Conformance - Action taken (or lack thereof) by the Federal Department User that results in a contravention of the rules governing the use of a MoS in the CPSS ePortal. However, the non-conformance does not meet the criteria applicable to either type of Major non-conformance.

• Observation - This type of finding will be applied in cases where, for example, information required to determine compliance cannot be provided, the lack of which has already resulted in the issuance of a Major non-conformance against a related element.

The Assessor Guidance Document may be amended from time to time.

Draft Final Report:

Once the assessment is completed, a Draft Final Report on the findings, covering each call-up/contract assessed, will be provided to the Federal Department User and their manager, with a timeframe to respond by accepting the findings or appealing the findings. The appeal must be in writing and include rationale and evidence to support the appeal. To be considered, any appeal must be made within 60 calendar days of the date of receipt of the Draft Final Report. Failure to respond within the stated timeframe will result in the findings being deemed as having been accepted and a note to this effect will be included in the Final Report.

Final Report:

Based on the outcome of discussions on the Draft Final Report, a Final Report will be prepared and sent to:

1. the Federal Department User's manager; and

2. OSME-SE; OSME–SE is responsible for communicating the findings to senior levels within the Client Department assessed and to work with the Client Department in establishing corrective measures (e.g. correct measures such as re-training to eliminate misuse of the self-serve procurement tool).

Selection Process [files to be assessed]

Step 1:

The initial list of potential assessments will be selected by using any or all of the following criteria:

1. using the list of Federal Department Users of the CPSS ePortal, combined with Utilization Reporting data, users will be selected from departments with a high business volume;

2. using information from past assessments to determine candidates for a follow-up assessment;

3. using the list of Federal Department Users of the CPSS ePortal, and information obtained from within STAMS which suggests possible misuse by a Client department.

Step 2:

Federal Department Users will be notified of the requirement for an assessment and, within a stated timeframe, will be required to:

• provide call-up/contract activity information necessary for the Online Services Division to determine the call-up(s) and contract(s) to be assessed; and to

• provide a copy of the information required to conduct the assessment.

Failure to respond/provide the above information within the stated timeframe will result in the Federal Department User's CPSS ePortal account being de-activated until a response is received. The Method of Supply Business Owner will be informed of the de-activation carried out by the Online Services Division and the resulting re-activation.

Step 3:

The call-up/contract information provided under Step 2 will be reviewed to identify the potential files for assessment, using, but not limited to the following criteria:

• High dollar value of original call-up or contract;

• Call-up or contract values that exceed the pre-defined dollar thresholds applicable to a MoS;

• Total cumulative value of amendments, against a single call-up or contract, in excess of $100,000 or 100% of the original call-up or contract value;

• Information that suggest the "under $25K" exception was used improperly;

• Information that suggest call-up/contract splitting may have occurred; or

• Information that suggests issuance of back-to-back call-ups or contracts may have occurred.