Thoughts on DFARS Case 2019-D009 — Use of Supplier Performance Risk System (SPRS) Assessments

The following DFARS case was published in the Federal Register last week. …

DFARS Case 2019-D009: Defense Federal Acquisition Regulation Supplement: Use of Supplier Performance Risk System (SPRS) Assessments

https://www.federalregister.gov/d/2020-18645

“DoD is proposing to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to update the policy and procedures for use of the Supplier Performance Risk System. … The Supplier Performance Risk System (SPRS) is a DoD enterprise application that retrieves quality and delivery data from Government systems to calculate “on time” delivery scores and quality classifications. Contracting officers will use the overall risk assessment generated by the SPRS module to evaluate quotes and offers received under all solicitations for supplies and services, including solicitations using part 12 procedures for the acquisition of commercial items. …”

The more I digest this, the more questions and concerns I have about how past performance data will be harvested and translated into the “SPRS Evaluation Criteria”
( https://www.sprs.csd.disa.mil/pdf/SPRS_DataEvaluationCriteria.pdf )

New DFARS Case 2019-D009: Use of Supplier Performance Risk System (SPRS) Assessments

DoD is proposing to amend the Defense Federal Acquisition Regulation Supplement (DFARS) to update the policy and procedures for use of the Supplier Performance Risk System. …

The Supplier Performance Risk System (SPRS) is a DoD enterprise application that retrieves quality and delivery data from Government systems to calculate “on time” delivery scores and quality classifications. Contracting officers will use the overall risk assessment generated by the SPRS module to evaluate quotes and offers received under all solicitations for supplies and services, including solicitations using part 12 procedures for the acquisition of commercial items. The system generates three risk assessments using the SPRS Evaluation Criteria and calculations at https://www.sprs.csd.disa.mil/pdf/SPRS_DataEvaluationCriteria.pdf. These risk assessments are described as follows:

• Item Risk. SPRS collects data to generate the probability that a product or service, based on intended use, will introduce counterfeit or nonconforming material entering the DoD supply chain, which can result in significant personnel safety issues, mission degradation, or monetary loss. SPRS “flags” items identified by Government sources as “high risk” and provides suggested mitigations, or as “not high risk”.
• Price Risk. SPRS collects historical pricing data from Government sources and applies a common statistical method to calculate the average price paid for a product or services, generating a price range that contracting officers can use in the evaluation of fair and reasonable pricing. Price Risk determines whether “a proposed price is consistent with historical prices paid for that item and is depicted by high, low, or within range”.
• Supplier Risk. SPRS calculates a supplier risk score, for contracting officers to compare competing suppliers. This score includes three years of relevant supplier performance information from existing Government data sources. … “

More at federalregister.gov

S.1790 – National Defense Authorization Act for Fiscal Year 2020

12/20/2019 – Signed by President; Became Public Law No: 116-92

Details at Congress.gov

 

FAR / DFARS CASE UPDATE (6 December 2019)

Status updates from the ‘Open Cases Reports’ …

NDAA2010§224 – Requiring Defense Microelectronics Products and Services Meet Trusted Supply Chain and Operational Security Standards

Per Conference report H. Rept. 116-333, the National Defense Authorization Act for Fiscal Year 2020 to be sent to the President includes the following section…

Update re: NDAA 2020 sections re counterfeit parts avoidance and trusted microelectronics

The Senate Bill for the National Defense Authorization Act for Fiscal Year 2020 (S.1790) modifies sections relevant to counterfeit parts avoidance and trusted microelectronics included in the House Bill. Here are the modified sections based on Conference report H.Rept.116-333 …

FAR / DFARS CASE UPDATE (22 November 2019)

Status updates from the ‘Open Cases Reports’ …

NDAA 2020 sections re counterfeit parts avoidance and trusted microelectronics

National Defense Authorization Act for Fiscal Year 2020 (H.R.2500) includes a few sections relevant to counterfeit parts avoidance and trusted microelectronics …

Section 230C, Trusted Supply Chain and Operational Security Standards for microelectronics
“… the Secretary shall establish trusted supply chain and operational security standards for the purchase of microelectronics products and services by the Department. …”

Section 254, Funding for Anti-Tampering Hetrogenous Integrated microelectronics
“… the amount authorized to be appropriated … is hereby increased by
$5,000,000 (with the amount of such increase to be made available for
anti-tamper heterogeneous integrated microelectronics). …”

Section 255, Briefing On Use of Blockchain Technology for Defense Purposes
“… the Under Secretary of Defense for Research and Engineering shall provide to the congressional defense committees a briefing on the potential use of distributed ledger technology for defense purposes. …”

Section 855, Supply Chain Risk Mitigation Policies to be Implemented Through Requirements Generation Processes
“… 10 U.S.C. 2302 note) is amended– … Development of tools for implementing supply chain risk management policies during the generation of requirements for a contract. …”

 

Thank you, Gerald Bogert.

FAR / DFARS CASE UPDATE (8 November 2019)

Status updates from the ‘Open Cases Reports’ …

FAR / DFARS CASE UPDATE (1 November 2019)

Status updates from the ‘Open Cases Reports’ …