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Background
Statutory Requirements and Definitions
Imaging Approach
Dept. of Financial Services Lessons Learned
Dept. of Transportation Lessons Learned
Agency Considerations
Timelines
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In 2011 the Legislature amended Section 215.985, F.S.,
making DFS responsible for the development and
maintenance of a contract reporting system.
In March 2012 Florida Accountability Contract Tracking
System (FACTS) came online.
FACTS Project Phases:
◦ Phase 1 – Web-based application for Contracts (Complete)
◦ Phase 2 – Budget and Disbursements (Complete)
◦ Phase 3 – Compliance/Audit Reporting (Complete)
◦ Phase 4 – Contract Images (Development Phase)
◦ Phase 5 – Grant Agreements (Development Phase)
◦ Phase 6 – Purchase Order Information (Testing Phase)
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In 2012 Section 215.985 (14), F.S. was amended to
require:
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By January 1, 2014, each state entity shall post to the
Florida Accountability Contract Tracking System
(FACTS) electronic images of contract and procurement
documents for each existing contract that was
executed before July 1, 2013, with payment from state
funds made after June 30, 2013.
Within 30 calendar days after executing a contract or
an amendment (including renewal, termination or
extension) each state agency shall update the required
information in FACTS.
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Contract – written agreement or purchase order
issued for the purchase of goods or services or a
written agreement for the receipt of state or
federal financial assistance
Procurement Documents – any document or
material provided to the public or any vendor as
part of a formal competitive solicitation of goods
or services undertaken by a state entity, and a
document or material submitted in response to a
formal competitive solicitation by any vendor
who is awarded the contract
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FACTS Images shall not reveal information
made confidential or exempt by law, including:
Statutory Exemptions
Trade Secret Laws
Chapter 119, Florida Statutes and
Two trade secret definitions:
Agency specific exemptions found in S. 812.081, Florida Statutes
other chapters may apply to specific S. 688.002, Florida Statutes
information.
Florida Statutes contain over 1,100
exemptions including:
• Social Security Numbers
• Personal Financial Information
• Medical Records
• Security System Plans
• Agency Building Plans
Section 815.045, Florida Statutes
Section 119.071(1)(f), Florida
Statutes
Sepro Corp. v. Florida Dept. of Envtl.
Prot., 839 So. 2d 781 (Fla. 1st DCA
2003). Trade secret owner must take
measures to protect specific
information.
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Agencies choose between two methods for
adding images to FACTS:
◦ Manual Upload – a users logs into FACTS, and
uploads files to the Contract’s Document Tab
◦ Batch Upload – agency sends a batch file with
image records (nightly), FACTS loads the
images systematically
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Technical Requirements for all images:
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Tagged Image File Formats (TIFFs) or Portable
Document Formats (PDF) are accepted
Agencies will add one file per record type/change
◦ Original Contract Document
◦ Amendment
◦ Procurement Document (New)
FACTS does not maintain image versions. Agencies
will replace old versions with new versions if
updates are needed
Ability to add multiple amendments records
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Contract Images
◦ Attach 2 types of contract images in FACTS:
1. Original Contract
2. Amendments
◦ Optionally, Agencies can provide a URL (to a document, not
a website) for each image in FACTS instead of uploading a
document
◦ Any URL’s included in FACTS should remain available for 10
years
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Procurement Images
◦ All procurement documents meeting the definition should
be included as one image in FACTS
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Add Contract images to FACTS
Choose a Document
Type and Browse to
attach the file.
• Original Contract
• Amendment
• Procurement
Document
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Add Contract URL and comments to FACTS
Optionally, include a
URL to a document.
Use the checkbox to
identify if the
awarded vendor’s
final proposal can
be found in the
original contract
document.
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Edit Contract Image Information in FACTS
• Use these links to Replace
Documents or Edit URL links
• Use the Delete button to delete
the entire row
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Access the Agency Image Report for all
agreements or search by a Contract ID to view
Contract Image Details.
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Public View of Contract Documents
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Background
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Policy Changes
◦ DFS “legacy” Contract Search site
◦ Included all two-party agreements and MFMP
service agreements only
◦ Did not include procurement documents
◦ Who was involved?
 Executive level (e.g. Chief of Staff, DCFOs, General
Counsel, IG)
◦ How engaged were policy makers?
 Fully engaged with monthly meetings to address new
and on-going scenarios requiring policy decisions
◦ What was the most challenging policy decision(s)?
 Confidential agreements
 “Specialty” agreements (e.g. data sharing, templates)
 Data elements to redact
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Policy Decisions (continued)
◦ How were policy decisions communicated?
 Phased approach with communications from:
⁃ Chief of Staff to DCFOs and Division Directors
⁃ DCFOs to Division Directors
⁃ Chief of General Services to Division Directors
⁃ Division Directors to Division Contract Managers
⁃ Contract Administration Manager to all Contract
Managers
⁃ Purchasing Manager to Purchasing Liaisons
⁃ Required training for all Contract Managers and
Purchasing Liaisons
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Process Changes
◦ Procurement
 Updated solicitation templates to incorporate changes
in law
 Communication to awarded vendors for all formal
solicitations notifying them of the new law and
requested:
⁃ Clean electronic copy of solicitation submission
⁃ Redacted electronic copy of solicitation submission
 Merged all solicitation/contract documents into one
attachment
 Updated two-party routing process to incorporate
required data elements and redacted documentation
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Process Changes (continued)
◦ Contracting
 Contract Administration Manager (CAM) reviews of all
two-party agreements prior to posting
 CAM monthly audit sampling of agreements posted
within FACTS to ensure accuracy
 CAM validation that all Contract Managers have
attended the required Advancing Accountability
training every two years as well as internal training
requirements
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‣ Process Changes (continued)
◦ Redaction
 Reviewed/updated redacted data elements
 Communicated redaction requirements to all contract
managers
 IT assistance with appropriate tool for secure redaction
(Adobe Acrobat X Professional multi-user license
through Citrix)
 Determined business areas without appropriate
redaction software (IT provided to those needed)
 Final stop in Purchasing Services for review prior to
posting
 WARNING: Vendor redaction may be excessive and not
in accordance with law (public records laws trump
vendor redactions)
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Implementation
◦ Engage Budget Office, Finance & Accounting and IT
Services to confirm resources and needs
◦ IT procurement of any necessary tools to support
all user needs
◦ Determine user access/Update user access
 Contract Administration Manager & Bureau Chief =
FACTS Administrator/Backup Administrator
 Purchasing Services = FACTS entry and loading of all
contracts and data elements (batching was utilized
only for initial implementation – individual entry may
be easier for smaller agencies)
 Finance & Accounting = Some need FACTS access to
view certain information related to vendor updates and
invoice processing
 Division Users = Redaction tool required for
proper/secure redaction
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Implementation (continued)
◦ Training
 Phased approach
⁃ Preliminary overview with all Division Directors,
Contract Managers and Purchasing Liaisons of roles
and responsibilities as it related to FACTS
requirements
⁃ “Road Shows” to each division location to train teams
and answer division specific questions and contract
scenarios
⁃ Required training for all Contract Managers to review
the “life cycle” of a contract from planning to
closeout
(158 contract managers trained in 15 sessions)
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Implementation (continued)
◦ Training (continued)
⁃ Continuing education done quarterly for new
Contract Managers
⁃ Contract Administration Manager internal file
reviews include an overview of FACTS
requirements
◦ Communication
 Communications from the Chief of Staff and DCFOs to
Division Directors stressing importance
 Training sessions listed above
 Return of incorrect/incomplete FACTS data or
documentation to the business area for correction
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On-going Support
◦ Contract Managers are responsible for submitting
and monitoring the data/documents within FACTS
to ensure accuracy
◦ Communication of any FACTS policy changes from
Purchasing to the Contract Managers/Purchasing
Liaisons
◦ Annual communication to all Contract Managers to
update their annual budget amounts
◦ Contract Summary Forms for agreements posted to
FACTS must come out of FACTS
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Construction Office was already storing
images in FDOT Electronic Document
Management System (EDMS)
◦ 1998/1999
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EDMS Procedure developed August 2007.
Batch upload program is tied to EDMS.
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FDOT FACTS Task Team- Responsible for
implementation
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Central Office Procurement
Office of Comptroller
Office of Information Systems
Construction Office
Office of General Counsel
District Procurement Offices
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Policy Makers for imaging, redaction, and
ensuring compliance:
◦ Assistant Secretary for Finance &
Administration
◦ General Counsel’s Office
◦ Central Office & District Administration
Managers
◦ District Secretaries
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Responsible for communicating policy
decisions:
◦ Procurement Office
◦ Office of Comptroller
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No procurement templates were modified
Notified Consultant Industry of new imaging
requirements of Section 215.985, F.S.
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Responsibility for uploading:
 The offices designated for preparing and
submitting contract status changes named
as responsible for uploading.
 All revenue agreements and grant award
agreements are the responsibility of the
General Accounting Office
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What documents would be included in the contract image?
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Original agreement
Supplemental
Amendment
Renewal
Task Work Order
Task Work Order
Amendment
Memorandum of
Agreement
Memorandum of
Understanding
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Master Agreement
Interagency
Agreements
Funding Authorization
Letter
Letter of Authorization
Termination Agreement
Certificate of
Completion
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Imaged only active contracts, where
payments were still being made.
Oldest contracts dated back to 2000.
Most are five or less years old.
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Responsibility of redaction:
 The offices designated for preparing and
submitting contract status changes also
responsible for redaction.
 All revenue agreements and grant award
agreements are the responsibility of the
General Accounting Office
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Information Redacted:
 Social Security Numbers
 Financial Account Numbers
 Vendor Financial Statements
 Professional Services Consultant Financial Audit Data
 Documents showing structural elements used in the
design and construction of FDOT Structures
 Security System Plans
REFERENCES:
Chapter 119 and Section 215.985, F.S.
23 Code of Federal Regulations (CFR) Section 172.7(d), Audits
23 United State Code (USC) Section 112(b)(2)(F), Pre-notification, Confidentiality of Data.
Procedure No. 050-020-026, Distribution of Exempt Documents Concerning Department Structures and Confidential
and Exempt Security System Plans
Procedure No. 325-060-001, Electronic Security for Public Records Exemptions
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Nuance PDF Converter Enterprise 8.0
($101.99/license).
PDF Converter Enterprise 8.0 Maintenance &
Support ($15.30/license).
Quote from SHI for the Nuance software licenses
Total of105 new licenses initial order
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FDOT provided training on Software
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Testing with Research, Safety, Professional
Services, Disbursement Operations,
Tallahassee and select District Procurement
Offices, and Construction Offices
◦ Initial Debug
Open testing up to more Districts
◦ Continuing Debug
Implement production with Research, Safety,
Professional Services, Tallahassee and District
Procurement Offices, and Construction
Offices
◦ Training and troubleshooting
Implement production with entire state
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Go To Webinars/Power Points
Guidance Documents on Redaction
Guidance Documents on what documents
to upload
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Instructors: Procurement Office & Office of Comptroller
Approx. 1,000 trained for initial phase
Approx. 182 trained for imaging phase
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Key Items covered during the Imaging
training
1. Requirements of the
application
2. The When, Where & Why of
Image Uploading
3. Redaction
4. The Image Upload Process
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Images are picked up twice daily
◦ Pick-up images at 12PM and at 3PM
◦ Zipped and batch uploaded daily by 6 PM
Image must be accompanied with a change type and
change description
When sending to DFS, image file and data file must
both be zipped then sent to
MFNFTP.FLDFS.COM/DOCUMENTS.
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Procedure- Contract Imaging for the Florida
Accountability Contract Tracking System
(FACTS), 375-030-035
Broadcast Status Updates to FDOT staff
Support in Central Office
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Link to FDOT Procedure:
http://www2.dot.state.fl.us/proceduraldocuments/procedures/
proceduresbyofficedetail.asp
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Contract Manager’s responsibilities:
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Ensure contracts have been uploaded correctly
and information has been redacted properly.
Ensure that all exhibits are attached.
Ensure that contracts reach DFS public site.
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Monitor Compliance
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Participate in a Legal Roundtable meeting to
discuss redaction and transparency topics:
Friday, September 27, 10:30 – 11:30
Betty Easley Conference Center, Room 152
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Identify Tools/Mechanisms for redaction
Establish and Communicate Agency redaction
policy and procedures
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Decide on Approach for loading images
• Online User Upload
• FTP Batch File Upload
• Requires a FTP account and working with your
agency’s technical staff
• Email FACTS.Info@myfloridacfo.com if you want
to Batch images to FACTS
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Identify and request any new FACTS users
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Agency FACTS point of contact will submit
request for new user access
Develop internal training plan
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October 2, 2013 - FACTS Images Go-Live
October 3, 2013 - Training Available for Online Users
October 7, 2013 – Workshop for Agencies
Using FTP Batch load
April 2, 2014 – Deadline for loading images
Images must be loaded for existing contracts
that were executed before July 1, 2013, with
payment from state funds made after June 30,
2013
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