Making Strategic Decisions Through Opposition and Uncertainty

Author: Shanna Webbers, Chief Procurement Officer, U.S. Internal Revenue Service.

IRS CPO Shanna Webbers reveals how her team tackled the task of modifying all their active procurement contracts with time quickly running out.

It was August 1, 2020. My team, “Team Procurement,” was laser-focused on meeting current obligations and knocking it out of the park for the fiscal year. But we had yet to finalize the implementation plan to comply with Section 889 of the Fiscal 2019 National Defense Authorization Act[1] by August 13. We had less than nine business days to figure it out. Although we knew it would be an extreme challenge, we still did not give up and aggressively sought a solution.

We had to work quickly and address myriad questions:

•  How many contracts will require a modification?
•  How will we monitor completion so we can quickly answer data calls?
• How will we consistently manage vendor exception requests?
• What is the potential backlash if we haven’t properly modified a contract and the vendor is using prohibited services or equipment?

First things first. I needed to understand the scope of the situation. We had approximately 2,700 active contracts. Our process takes about two hours on average to complete a modification, input data into the Federal Procurement Data System-Next Generation (FPDS-NG), and upload the document in our contract file repository. So, worst-case scenario, it could take up to 5,400 hours—or 2.5 years—to modify 100 percent of our active contracts.

Did I mention we only had nine days?!

To narrow down the scope, we used the Product Service Code to identify 1,466 contracts that met Section 889 criteria. Based on our current process it could still take up to 3,000 hours—or a full year—to get this finished. There had to be a quicker way.  

We had successfully used a Robotic Process Automation (aka “bot”) to correct data errors in the FPDS-NG earlier in the year, but we hadn’t used it for any other purpose. We knew the bot could update FPDS-NG in seconds, but we didn’t know if it could create contract modifications in bulk. There was a lot of angst and opposition about using the bot for this purpose. I listened to various concerns and reasons that this might not work. Each had merit and deserved consideration when assessing our options. I was convinced that the bot was our best path to success, so I continued to probe with more questions that would highlight the risks.

We didn’t have all the answers and there were a lot of disparate data points to consider. I had learned early on in my career to trust my instincts. At the end of the day, as chief procurement officer, I was ultimately responsible for meeting the implementation timeline and managing risk. I decided to move forward with the bot effort, even though there was much uncertainty and disagreement within the team about which approach was best. I was willing to accept the risks and give it a try, especially since I didn’t see any other way to modify thousands of contracts in such a short timeframe. Plus, if the bot didn’t work as expected, we could pivot to Plan B: using our current process. Either way, we would get it done, but the bot would produce results in a much shorter timeframe.

Once my decision was made to pursue the bot solution, we created a solid path forward within a week that could be implemented quickly, and with minimal risk. Our approach was simple. We:

•  Tested and confirmed the bot could accurately create modifications in bulk.
•  Created a unique e-mail address for vendors to submit questions and exception requests.
• Used a modification number ending in “889A” for quick identification.
• Selected a dozen contracting officers to sign the modifications.
• Received interim approval for the bot to upload modifications into the contract file repository.
• Used the bot to e-mail 1,466 modifications to the appropriate vendor.
• Added Section 889 clause to our contract writing system for new awards.

Even with this approach, I knew we still couldn’t meet the August 13 deadline. So, we sent a letter explaining our implementation approach to every contractor in our database and established a deadline for submitting an exception request. These would be our priority since it had the highest risk, but no exceptions were received.  

While we didn’t meet the August 13 deadline, we did accomplish a task of this magnitude in record time. More importantly, we pushed outside of our comfort zone and still were successful. The route you know is not always the best route. We are operating in a constant state of uncertainty during this COVID-19 pandemic; when uncertainty exists, you need to think outside of the box to find new solutions. It might even reveal opportunities that were not apparent before. As a leader, you must be able to manage risk, push your team outside their comfort zone, and take a chance when the opportunity presents itself.

We used an unproven approach and it paid off. The return on investment (ROI) was impressive. In addition to reducing the administrative burden on contracting officers and eliminating data errors, the total time savings[2] went from ~1 year (2,860 hours) to ~3 days (72 hours). Plus, it didn’t require additional funding or other resources to implement this effort. IRS Team Procurement rocks!

But we didn’t do it alone. Our CIO and IT partners deserve a special shout-out. By providing interim approval for the bot to access our contract writing system, we limited the amount of human intervention required in the process, thus maximizing ROI.

Just remember, the perfect contract is only one modification away. Now is the time to take a chance—so go forth and make great things happen.

One team! One procurement! One IRS! CM

Endnotes
[1] National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2019 (Pub. L. 115-232), Section 889(a)(1)(B) prohibits executive agencies from entering into, or extending or renewing, a contract with an entity that uses any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system, on or after August 13, 2020, unless an exception applies or a waiver is granted.

[2] Time for a contracting officer to manually create one modification, input data into FPDS-NG, and upload modification into the contract file repository is about two hours (120 minutes average). In contrast, the bot created the modification in one second, input data into FPDS in less than one second, and uploaded the modification in three minutes, on average.