TOPICS
TOPICS
Procurement policy office issues new guidance on interagency acquisitions
The Office of Management and Budget's Office of Federal Procurement Policy on Friday released new guidance on interagency acquisitions. The 70-page document included a checklist of roles and responsibilities for agencies throughout the life cycle of an interagency contract.
OFPP Administrator Paul A. Denett told senior procurement executives in the memo that the guidance was designed to help agencies make sound business decisions to support the use of interagency acquisitions and strengthen the management of those agreements.
"Lack of clear lines of responsibility between agencies with requirements (requesting agencies) and the agencies which provide acquisition support and award contracts on their behalf (servicing agencies) has contributed to inadequate planning, inconsistent use of competition, weak contract management and concerns regarding financial controls," Denett wrote.
Management of interagency contracts has been an area of concern for some time, appearing on the Government Accountability Office's list of high-risk federal programs since 2005. Several agencies, including the Defense and Homeland Security departments, have come under congressional scrutiny for their interagency acquisitions.
"It's pretty clear there's been a screaming need for this kind of guidance," said Alan Chvotkin, senior vice president and counsel for the Professional Services Council, an Arlington, Va.-based industry association. "I'm glad it's out and I hope it'll have some light well after this administration leaves office. It's one of those documents that could help get interagency acquisitions off the GAO high-risk list."
There are two primary categories of interagency acquisition -- direct and assisted. In a direct acquisition, the requesting agency places a task or delivery order through the servicing agency's indefinite delivery vehicle, such as a governmentwide acquisition contract or multiple award schedule. While the servicing agency manages the vehicle, it is not responsible for oversight of the task or delivery order.
OFPP's most recent guidance focuses largely on assisted acquisitions, in which the requesting agency contracts the servicing agency to perform acquisition activities on the requesting agency's behalf. The servicing agency may award a contract, task or delivery order in addition to managing the overall vehicle under which orders are placed.
The first appendix to the memo is a checklist of roles and responsibilities in assisted acquisitions. The list identifies 16 primary responsibilities over the life of such procurements and makes general recommendations as to each agency's role. While the checklist is comprehensive, the memo warns that it should be used "only as a starting point." The guidance urges each agency to ensure its policies establish clear roles and responsibilities depending on its own needs and circumstances.
In addition to the checklist, OFPP provides agencies with key elements of a model interagency agreement for an assisted acquisition, as well as a template agreement and an example of the finished product.
Denett said the guidance reflected comments from a number of stakeholders, including agency chief acquisition, financial and information officers and GAO.
"This was developed with collaboration with the federal agencies," Chvotkin said. "It's not just Paul Denett or Mathew Blum, [OFPP associate administrator] sitting in the ivory tower of OMB writing this up. So I think it will be useful as a guide."
Denett advised acquisition officials to work with program managers, contracting officers' technical representatives, finance officers, information technology officers and legal staff to ensure the guidance is implemented effectively and complies with existing requirements.
COMMENTS
- How did we get into this mess? Here is one theory. OFPP was always sympathetic toward Big Business. Big Business wanted a simple way to market services to multiple agencies and contracting vehicles that would allow them to do so. The interagency contractors would "profit" by charging fees to federal customers who used the contracts. It was a nice pass back scheme for GSA and other interagency sponsors including Department of the Interior who received a share of the proceeds. Everybody would be happy because it was quick and painless. OFPP sold the idea to Congress, Big Business lobbyists did their thing, and the legislation passed. Remember the Abu Ghraib prison abuse scandal? Sure, everybody does. The interrogators were provided through a Department of the Interior interagency contract. The contract was for information technology not interrogators, there was no direct control over the contractors in Iraq, and the contract that provided them had no performance standards. Consequently, the contractor got paid. Here we are years later trying to clean up the numerous messes that were born out of interagency contracting. KO Posted June 11, 2008 10:57 AM
- It's about time! Thanks to OFPP for publishing this. Yes, it is 70-pages, but if agencies actually follow the process outlined in this document, they should reduce the types of issues that placed this practice on GAO's list. Does it establish a disciplined process, increase accountability and coordination, require fairly standard documentation, and perhaps reduce some flexibility; yes. Unfortunately, it does nothing to increase public transparency; however, there are now a few more documents that can serve as a decision audit trail. Peter G. Tuttle, CPCM Posted June 10, 2008 1:05 PM
- Just what we need - more guidance. No one on the front line has the time to read a 70 page document. We don't need more guidance(= Help ???), we need more people Michael McManus Posted June 10, 2008 12:36 PM
