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.