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Regardless of what others may preach, I believe that the new A-76 process truly favors industry. The new guidance requires agencies to finish studies in only 12 months, but it does not provide funding and training to conduct studies. It is always easier to make rules than to make rules that provide resources and the capability to comply with new regulations.

If the government continues the insanity of A-76 job competitions, rather than using other, more sensible business process improvement techniques to promote efficiency, A-76 training is essential for agency employees to have a chance at winning. But since few in-house assets are available to train federal personnel, we have to rely on consultants. These days, most A-76 experts generally aren't working in government; they work for Beltway bandits. Unless we in government start developing our own internal consultants, completion of standard competitions in 12 months will be very hard to achieve, even with the very best front-end planning and program execution.

The new A-76 has not changed the contracting process - only the timelines have been shortened. Each step in the process comprises a number of actions that must be resolved quickly by a wide range of personnel, most importantly contracting officers. To expedite this process, some steps can be conducted simultaneously, and agencies can do more planning before announcing a competition. But the major problem for all non-Defense agencies is a lack of A-76 knowledge for the teams that write the performance work statement, which is the set of requirements for industry and in-house bidders.

And there are always problems that crop up with any solicitation, A-76 or otherwise. Under the new circular, agencies must still conduct pre-planning, write the performance work statement, issue the solicitation, develop the in-house bid, handle amendments to the solicitation, analyze proposals, and deal with possible protests. Will we really be able to do it all in 12 months? Competing a function in this timeframe will require proactive leadership, total devotion and commitment. Will we have that? I doubt it. I know some organizations that have proactive leadership, but ask yourself, does yours?

One solution, of course, is to rely on Beltway bandits. Although there are many consultants out there who perform A-76 studies, only six or seven firms in the Washington metropolitan area are true subject matter experts in the process - and that's because A-76 has been their bread-and-butter business. Further, while many firms have a few consultants who are truly knowledgeable, these personnel are in such demand that you rarely see them after a company finishes its sales pitch. So what do these firms do? They hire young college graduates to collect and analyze data, and too often end up with flawed and poorly validated results. The wasted time and expense hurts federal agencies and employees who rely on the consultants for their expertise also suffer.

The Defense Department made a huge mistake in the 1990s when it eliminated its in-house capacity to provide A-76 training and help run studies in the field. In the 1980s, the Navy had a crack Commercial Activities Management Team under the chief of Naval Education. The Air Force and Army had similar teams. But for whatever reason, Defense decided civil servants should not be doing their own teaching and internal consulting. Today, we no longer get internal quality and sensitivity. Instead, we get outside guidance that too often is poorly crafted. And that ends up hurting federal employees.

If you want to succeed at competitive sourcing under the new A-76, my advice is to budget for the development of internal teams and do the job yourself. Agencies must take the necessary step of hiring, grooming and training their own in-house consultants, who will "own the process" and provide continuity. We cannot and should not totally rely on Beltway bandits. We in government have a basic duty to oversee products developed by consultants to ensure they are absolutely correct and meet our needs, and work to make us competitive against industry. We cannot afford to drag our feet anymore. Get all the training you can, and take the lessons learned over the last 20 years to heart. You may win.

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