The President has proposed a two-year pay freeze for federal employees; the House of Representatives wants to extend that to five years. Others have proposed legislation that would freeze federal hiring all together. “The government is bloated and too big” goes the conventional wisdom. If you’re a government contractor that “wisdom” could have a profound negative impact on your government business.
Let’s start at the top. Say you’re a company that wants to get a government contract. Be prepared to stand in line. A hiring freeze would mean that the already stretched-thin acquisition workforce will likely get thinner. There will be fewer people (likely with less overall experience) to handle your offer.
Even a pay freeze would impact your business, as qualified acquisition professionals look elsewhere for jobs and those that do remain could have morale issues.
Let’s say your company already has a government contract. Monday, your firm announces a new hot product. You’ve been told that you must get this on your company’s federal contract – fast. Well, not so fast. Fewer acquisition professionals, or even the same amount as we have now, means that there is little ability for the government to move quickly to modify existing contracts. If government customers want your product they will have to take the extra steps necessary to buy it on the open market, a time-consuming process not favored by overworked government contracting officers.
“I’m in sales,” you say? Let’s take a look at the impact of a pay or hiring freeze on your business. There may be good and bad here, depending on what you’re selling.
For product-oriented companies, a static or shrinking federal workforce means that there will generally be less need for the product’s you’re selling, particularly in a tight budget climate. Fewer people mean fewer chairs, desks, real estate, paper, etc. To survive, you must ensure that your efficiency and value propositions literally jump off the page. It must be crystal clear how spending money with you will save the government money overall.
Service providers might have it slightly better. The government will still be expected to meet many missions, and if there aren’t enough federal workers to fill the need, this could translate into increased opportunities for service providers. You certainly have to deal with the same tight budgets that everyone else has to, so I wouldn’t start predicting year-over-year sales jumps. Still, with House Republicans resuscitating competitive sourcing (which allows contractors to bid against government for work currently conducted by federal employees), and continuing public demand for federal services, you have an opportunity to place people where they’re needed most. Added bonus: It might be easier to pick up qualified “frozen” federal workers to perform those tasks if you can offer competitive compensation and the prospect of a pay “thaw.”
The bottom line for contractors: When federal workers are frozen, you’ll feel the chill too.
– by Larry Allen – Washington Business Journal – February 23, 2011
Read more: Federal pay freeze: Why it matters | Washington Business Journal
If the government shuts down, the closings in the mid-1990s are not good indicators of what’s to come for government contractors.
Contractors would get hit harder today if agencies closed their doors than they were 15 years ago, said Alan Chvotkin, executive vice president and counsel for the Professional Services Council, an industry group.
Government spending on contracts has increased radically compared to the last shutdown, which stretched from Dec. 16, 1995, to Jan. 6, 1996.
And the government buys more services than products today. Contracting for services increased by 17 percent per year between 2000 and 2008, according to the Office of Management and Budget.
As a result, a shutdown would tear into service contractors’ pocketbooks. Services aren’t paid for when the contract is signed, Chvotkin said. They can be paid a number of different ways, from quarterly payments for their work to jobs done per day. Product sellers won’t be hit in the same way. They will face changes in when and where they would make their deliveries, but the government likely will have already paid the companies for products.
1995 is no guidepost for what could come very quickly, he said. There have even been major reorganizations in 15 years, including the addition of the Homeland Security Department that is made up of a conglomeration of numerous agencies.
“A lot is the same — but significantly different,” he said.
The Professional Services Council is hosting a conference on dealing with a possible shutdown. Chvotkin and two Clinton administration officials who served in the White House during the 1995 shutdowns will take part in a discussion Feb. 23 about the effect a government shutdown could have on the government contractor community.
“It’s a program we wish we didn’t have to have and give information that no one really needs,” he said. But “no one is going to be immune from the impact.”
– by Matthew Weigelt – Federal Computer Week – Feb. 22, 2011
The process for issuing federal acquisition rules has become too slow and uncoordinated and must be dramatically revamped, according to top officials at the General Services Administration.
In recent years, the multiagency Federal Acquisition Regulations Council, the entity in charge of developing and codifying government procurement rules, has become bogged down in a cumbersome rule-making process that has created an unmanageable backlog of cases, many dating back several years, the officials said.
For example, in fiscal 2010 the FAR Council, which has representatives from the Defense Department, GSA and NASA, opened 36 cases and closed 42 others. But at the end of the year, 61 potential rules remained outstanding, meaning in most instances, rules took more than one year to finish. Some have taken up to five years, according to Kathleen Turco, associate administrator of governmentwide policy at GSA.
“If it takes that long, it’s not really good rule-making,” Turco said. “We want quality but not looking at timeliness is not acceptable either.” Typically, even a complicated rule should take less than one year, she said.
Looking to rectify the problem, leaders of the FAR Council and the Office of Management and Budget’s Information and Regulatory Affairs and Federal Procurement Policy shops, held a first-of-its-kind meeting on Feb. 9 to begin hashing out the process for reforming the outdated rule-making system.
Attended by 35 agency officials at GSA headquarters, the event was coordinated as a “slam,” in which key decision-makers lock themselves in a room to solve one problem and cannot leave until specific outcomes are achieved. GSA has hosted two previous slams on information technology and hiring for the acquisition workforce, but this was the first interagency event.
The meeting helped identify a number of causes for the backlog, including a lack of leadership on rule-making, particularly from GSA; a failure to elevate concerns to senior management; a high number of retirements and turnover; and insufficient interagency coordination.
“We need a tune-up on our system,” GSA Administrator Martha Johnson said. “Right now, we are driving our father’s car. It works, but is showing its age. I want a modern, electric car version of the FAR to take us where we need to go reliably and quickly.”
Officials during last week’s meeting identified three fundamental areas in need of examination: team management, case management and training. In each area, participants agreed to create action plans with projected milestones due by March 31.
“The slam was a huge success in effectively and efficiently getting all of the participating agencies to agree on these three key improvement areas,” said Bill Roets, senior procurement analyst in NASA’s Office of Procurement. “We are looking forward to working with the other federal agencies on these improvement areas and improving the FAR rule-making process.”
For example, the FAR Council currently is broken into six teams, with each devoted to a certain area of expertise such as small businesses, finance or technology. One of the three agencies represented on the council will take the lead in the effort, bringing in outside experts if necessary. The new review, to be led by NASA, will examine whether the FAR teams are structured correctly and coordinated most efficiently.
A second review, which Defense will lead, will examine the steps of the rule-making process, including rapidly resolving critical policy decisions, cutting the overall backlog, ensuring communication among the teams and bringing legal counsel in at the front end, Turco said.
The third examination, to be run by GSA, will look at enhancing the training program for FAR Council employees, many of whom have been on the job for less than one year. “We bring them on at GS-14 and 15 [levels] with a wealth of experience in procurement and contract management, but actual rule-making and policy drafting is an art all of its own,” Turco said. “We need to ensure they have training.”
While training is a concern, staffing for the council is not the problem, she said. GSA has 15 full-time employees devoted exclusively to studying, writing, editing and drafting acquisition rules. Previously, Turco said, many of those same workers would have multiple duties unrelated to the FAR.
“The structure of the office over here at GSA was convoluted and a mess,” she conceded.
But, other problems persist. In late March, Turco plans to address the lengthy and often unwieldy administrative process needed to submit a document to be published in Federal Register.
The working groups also will consider developing a collaboration tool — possibly a Google application — where the teams can work together online. Incredibly, much of the rule-making process, including the submission and editing of public comments, still is done on paper, contributing to the backlog, she said.
Once the backlog problems are addressed, senior leaders of the council plan to tackle the quality of the rule-making process, which Turco said has frequently devolved into “mommy management.”
“We are co-mingling rule-making with process,” she said. “We are too dictatorial in terms of how people carry out the policy and it is getting silly. We are co-mingling what we are supposed to be doing. Rulemaking is not telling people how to get from Point A to Point B.”
– by Robert Brodsky – GovExec.com – February 15, 2011
Filed under GTPAC News · Tagged with 8(a), Albany, bid proposal, capabilities statement, Commerce Dept., IRS, Marines, minority owned business, service disabled, small business, state & local, subcontracting, veteran owned business, woman owned business, wosb
Ever heard of “speed dating” where couples are matched for short periods of time to see if the chemistry is right?
Well, through a unique event on February 22, the same principle is being applied – EXCEPT it involves matches between local businesses, government agencies, and prime contractors.
If you want the opportunity to meet with buyers from local, state and federal agencies, you can’t afford to miss this event!
On Tuesday, February 22nd, the Albany (GA) Civic Center is the place to put your best marketing techniques to work. You’ll get a chance to meet with — and present your capabilities to — decision-makers and buyers from representatives of local, state, and federal government agencies, including the State of Georgia, the University System of Georgia, the Georgia Dept. of Corrections, the City of Albany, the Southwest Georgia Regional Airport, the Marine Corps Command, the IRS, the General Services Administration, and the federal departments of Commerce, Interior, and Juvenile Justice – among others scheduled to be in attendance.
Along with 15-minute one-on-one meetings with buyers and contracting officials, attendees will have a chance to attend briefings on each of these topics:
- Business Communications, Elevator Pitches and Capability Statements
- Reading and Responding to Bid Solicitations
- The Do’s and Don’ts of Government Contracting
- Government Market Research
- SBA’s New Women Owned Small Business (WOSB) Certification Program
The featured luncheon speaker for this very special day is Ms. Pat Hanes, Regional Director of the Atlanta National Enterprise Center with the Minority Business Development Agency (MBDA) of the U.S. Department of Commerce.
Coffee and informal networking begins at 8:00 am. The day’s program begins at 9:00 am and runs until 3:00 pm.
This event is completely free, so register now! Simply click here to register and then hit the “Sign Up” button.
The Small Business Administration has finalized the most comprehensive changes to its 8(a) small and disadvantaged business contacting program in more than a decade, with a sharp focus on reforming and improving the transparency of Alaska native corporations.
The long-awaited final rules, published Friday in the Federal Register, closely mirror — except for minor technical changes — the proposed rules offered by SBA in October 2009.
The lengthy final rule, which takes effect on March 14, attempts to tackle a host of 8(a) concerns, from the threshold to enter and remain in the program to tightening the rules for joint ventures and mentor-protégé relationships.
“SBA has learned through experience that certain of its rules governing the 8(a) [Business Development] program are too restrictive and serve to unduly preclude firms from being admitted to the program,” the rule states. “In other cases, SBA determined that a rule is too expansive or indefinite and sought to restrict or clarify those rules.”
The agency conducted public meetings in 10 cities and consulted with tribes in two others. SBA received more than 230 comment letters.
“Through public meetings held in cities throughout the country, SBA gained valuable input from members of the small business community on ways to strengthen the program to provide the best opportunities for eligible firms, while also stepping up efforts to combat waste, fraud and abuse,” said SBA Administrator Karen Mills.
Arguably the biggest change affects ANCs, controversial 8(a) subentities that can win sole-source contracts of any size. For the first time, firms owned by ANCs or by Indian tribes, Native Hawaiian organizations and community development corporations will be required to report the financial benefits flowing back to their communities. Several recent news reports and congressional investigations have questioned whether the profits from ANCs are reaching disadvantaged Native Alaskans.
Each firm now will be required to submit information relating to their funding of cultural programs, employment assistance, jobs, scholarships, internships and subsistence activities, SBA said. In a change from the proposed rule, only the parent company, rather than the individual businesses or subsidiaries, will be required to report. Also, the agency delayed implementation of this provision for six months to allow further meetings with the tribal and ANC community, said John Klein, SBA’s acting director of government contracting and assistant general counsel for procurement law.
Devon E. Hewitt, a partner in the Washington law firm of Piliero Mazza, said the change recognizes the intense scrutiny ANCs are facing from Congress and watchdogs. “The question is whether they have done enough,” Hewitt said.
But some lawmakers want to go further in reforming the ANC program. On Thursday, Rep. Bennie Thompson, D-Miss., ranking member of the House Homeland Security Committee, introduced a bill that would put ANCs on equal footing with all other small businesses operating in the 8(a) program. The bill is a companion to legislation previously introduced by Sen. Claire McCaskill, D-Mo.
“All too often, small businesses are crowded out of opportunities by Alaska native corporations that receive uncapped, no-bid contracts under a special provision of the 8(a) program,” Thompson said. “This bill will assure that ANCs cannot continue in a privileged status that both protects them from legitimate competition from other businesses and fails to return a fair share of profits to Native Alaskan shareholders.”
The SBA regulations make other attempts to regulate the behavior of ANCs. Firms graduating from the 8(a) program no longer will be allowed to hand off contracts to a new subsidiary owned by the same ANC. “There is a perception that these contracts are being passed from one firm to another,” Klein said.
Several ANCs that have proposed changes to the 8(a) program applauded the rules change. “The rule-making process has been long and difficult for the Alaska native community,” said Rex Rock Sr., president and chief executive officer of Arctic Slope Regional Corporation. “The SBA struck a meaningful balance by protecting government and taxpayer interests while continuing to provide economic opportunities for disadvantaged businesses.”
The final rule also makes several significant changes to the rules guiding joint ventures, which are created when a small business partners with a non-8(a) firm, typically a larger business. These joint ventures are considered small businesses eligible to receive high-value contracts without competition.
The rule attempts to assure that the nondisadvantaged firm does not unduly benefit from the program. The 8(a) partner of the joint venture must now perform at least 40 percent of the work, including those awarded through a mentor-protégé agreement. The previous statutory language required only that the small business perform a “significant portion” of the work, Hewitt said.
Joint ventures awarded to an 8(a) firm also will not be allowed to win more than three contracts during a two-year period, and these entities cannot subcontract work to a non-8(a) joint venture partner. Plus, mentors who do not provide assistance to their protégés could face consequences ranging from stop-work orders to debarment.
Other proposed changes would clarify the size, income and familial determinations needed to be eligible for the 8(a) program, including those:
- Excluding the individual retirement accounts from the strict net worth calculations that are used to determine eligibility for the program;
- Raising the adjusted gross income to enter into the program from $200,000 to $250,000 (the total value of the participant’s assets needed to enter the program was increased from $3 million to $4 million);
- Increasing the adjusted gross income for continued eligibility for the program from $300,000 to $350,000 (the asset level was bumped from $4 million to $6 million);
- Allowing immediate family members of a current or former program participant to own an 8(a) firm if they are qualified to run the business and are judged not to be a front for their family member’s company;
- Requiring that a firm’s size status remain small for its primary industry code during its participation in the 8(a) program;
- Limiting the type and amount of fees an agent or representative can charge for assisting an 8(a) firm (the rule prohibits unreasonable fees as well as arrangements in which the fees are a percentage of the contract award or revenue); and
- Allowing owners of 8(a) firms called to active military status to elect to be temporarily suspended rather than lose any of their nine-year term in the program.
– by Robert Brodsky – GovExec.com – February 11, 2011
Transparency, apparently, has its limits.
The Obama administration announced on Thursday it was withdrawing a proposal that would have required federal agencies to post copies of contracts and task-and-delivery orders on a public website.
Last May, the civilian and defense acquisition councils, which craft changes to the Federal Acquisition Regulation, published an advance notice of proposed rule-making. The councils said at the time they were seeking public comment on how best to amend the FAR “to enable public posting of contract actions, should such posting become a requirement in the future, without compromising contractors’ proprietary and confidential commercial or financial information.”
The councils heard from 15 respondents, including agencies, industry associations, advocacy groups and private individuals. Most of the responses criticized the plan as difficult to implement, unnecessarily burdensome to industry and a deterrent to competing for government work.
One respondent noted, “With more than 30 million transactions issued by the government annually, the redaction process alone would be overwhelming.”
Faced with stiff opposition and scarce resources to implement their proposal, the councils announced they were abandoning the effort. The notice said some of the information that would be disclosed already is available on federal websites and many nonclassified contracts can be obtained through a Freedom of Information Act request.
The councils also acknowledged the government does not have the capability or the resources at this point to guarantee that proprietary information would be protected if the proposal was implemented. The civilian and defense acquisition councils, which represent the Defense Department, General Services Administration and NASA, acknowledged the government runs the risk of lawsuits if they inadvertently release private information.
“The ongoing efforts to identify protections essential for safeguarding unclassified information are not yet sufficiently mature that such efforts can be bypassed to establish a contract-posting requirement prior to guidance on unclassified information,” the notice said. “To avoid inadvertent disclosures, the government would be required to review contractor-redacted documents before such items are posted to a public website.”
The proposal, which had drawn the ire of many industry groups, was pulled back on the same day House lawmakers debated whether agency regulations were stifling job growth.
The councils cited the costs associated with the plan, including technology, software and the time of contractor and government employees. “DoD, GSA and NASA advocate a judicious approach to establishing contract-posting requirements, one that will appropriately conserve resources and identify information that should be protected from general release to the public,” they wrote.
Ironically, the administration’s decision runs directly counter to a proposal then-Sen. Barack Obama had supported. While on the presidential campaign trail in 2008, Obama, along with Sens. John McCain, R-Ariz., and Tom Coburn, R-Okla., unsuccessfully proposed a bill that would have required agencies to post all contract documents online.
Obama’s Office of Management and Budget reaffirmed the administration’s commitment to posting contracts online in August 2009.
“I know there was opposition to the transparency proposal, but I thought that the public was in good hands since Obama supported spending transparency while in the Senate and on the campaign trail,” said Scott Amey, general counsel for the Project on Government Oversight, a watchdog group that backed the proposal. “I guess it’s harder to promote change from inside the White House.”
Amey argued federal websites that track contract spending provide only summary data while the FOIA process is often so slow that a long-term contract can be completed before the document is provided to a requestor.
The councils said they could revise the proposal at a later date, but such a plan would have to include a high-dollar threshold for contracts, a requirement for the successful offeror to redact portions of the contract and an incentive for the company to allow the contract to be published.
– By Robert Brodsky – GovExec.com – February 10, 2011
President Obama’s fiscal 2012 budget, scheduled to be released on Monday, will streamline, and in some cases, eliminate entirely, several small business programs, according to Small Business Administrator Karen Mills.
Last month, Sens. Mary Landrieu, D-La., chairwoman of the Small Business and Entrepreneurship Committee, and Olympia Snowe, R-Maine, the panel’s ranking member, sent a letter to Mills and SBA Inspector General Peg Gustafson seeking recommendations for programs that could be “eliminated, or substantially reduced without undermining the SBA’s ability to serve the needs of small business owners.”
On Friday, Mills responded in a one-page letter in which she declined to provide details of any program cuts before the fiscal 2012 budget is submitted to Congress.
But, in a sign of what might be on the horizon, Mills hinted that the agency, which already has experienced years of flat or declining spending, could face even leaner times.
“With respect to delineating specific programs that we believe are redundant or duplicative, on Feb. 14 the president will release his fiscal 2012 budget proposal, which will identify SBA programs that can be further streamlined, or in some instances eliminated altogether,” Mills wrote.
It is not clear which programs are on the chopping block. In the letter, Mills said she, or SBA senior program officials, would be available to discuss the cuts after the budget has been released.
“Over the past two years, the agency has made considerable progress in this area,” Mills wrote. “Plans are in place to continue to use technology and other cost-saving approaches to continue to streamline activities and make the best use of the taxpayers’ dollars.”
The IG’s office said it has not yet completed its response to the letter.
The Senate committee is planning to hold a hearing this month on proposed SBA program cuts.
– by Robert Brodsky – GovExec.com – February 9, 2011
When the Obama administration released figures showing that Uncle Sam spent less on outside contractors for the first time in 13 years, the data pointed to a little-publicized difference in the way Democrats and Republicans approach deficit reduction.
Spending on contractors may not be as sexy as other items, but it’s a difference that has serious implications for federal employees.
In fiscal 2010, $535 billion was spent on those services, $15 billion less than the year before, officials at the Office of Management and Budget said Thursday.
“Under the prior administration, spending on government contracts more than doubled,” said Jeffrey Zients, OMB deputy director for management and the administration’s chief performance officer.
They were blowing their own horns while taking a swipe at Republican policies, but the money they were talking about is significant.
If the Obama administration’s spending on contractors had continued at the Bush administration’s rate, the government would have spent $80 billion more in 2010, according to the OMB.
“We have reversed the trend of uncontrollable growth, and we’re saving money and making sure every taxpayer dollar is being well spent,” Zients said.
The key, added Daniel Gordon, OMB’s administrator of federal procurement policy, was “buying less and buying smarter.”
Although some cuts in contract spending had to do with such things as weapons systems and fuel, Gordon said OMB is working with agencies to reduce spending on professional and technical services, which has grown disproportionately in recent years.
“We see significant potential for savings,” he added. “The president’s budget for fiscal 2012 will call for a reduction in categories that include these services, but we need to start the savings now, in fiscal 2011, and we will be working with the agencies to do that.”
The savings OMB announced certainly won’t solve Washington’s financial problems, but every dollar counts. Yet when some deficit hawks look for places to cut, they manage to ignore contractor spending while making sure they target federal employees.
When the Republican Study Committee, for example, issued its long list of proposed cutbacks, “federal workforce reforms” were near the top. They included freezing civilian pay for five years, instead of the two years already imposed, and cutting the workforce by 15 percent through attrition.
The committee did mention contractors near the end of its list, but not as a way of cutting spending. Instead, the Republicans recommended a change in policy that would allow more of Sam’s work to flow to the private sector. While almost every other item on its long list indicated an amount that could be saved by cuts, no dollar figure was attached to the call for more “competitive sourcing of government services.”
The difference in approach between the White House and Republicans is an important one for Frankie and Flo Fed.
Federal workers have long complained that contractors too often do work that should be reserved for employees. Some of this is about turf. Federal labor unions, for example, want to keep as much federal work as possible for federal workers, because that’s who their members are.
But much of it is about the governmental imperative that “inherently governmental” work should be done by people directly on Sam’s payroll. Collecting taxes certainly is an inherently government task, but outside contractors had been doing some of that work until the Obama administration put a stop to it last year. An Internal Revenue Service statement at the time said that “IRS collection is more cost-effective than the contractors.”
Last year, the chairmen of the National Commission on Fiscal Responsibility and Reform proposed eliminating 250,000 non-defense contractors who provide services and augment the workforce. The chairmen also suggested slashing spending for contractors who assist Pentagon staff by 20 percent each year from fiscal 2011 through 2013.
The Republican committee, however, says contracting may be the frugal option.
“Our focus in allowing competition from the private sector is to reduce overall spending. If taxpayers get a better deal by having nongovernmental activities like lawn mowing performed by a contractor, it only makes sense to do that,” said Brian Straessle, a spokesman for the committee. “If having federal employees mow the lawn is cheaper, let’s do that. The point is, there should be an option.”
Although the IRS found it could conserve funds by using federal employees instead of contractors, OMB officials did not claim that the savings they announced were the result of having employees perform jobs formerly given to outsiders.
In fact, Gordon said, “we never viewed insourcing as a way of getting dramatic savings. . . . We view it as a good-overnment management initiative.”
One good-government initiative was strengthening the notoriously weak acquisition workforce – the federal employees who work with contractors to make sure they deliver, as Gordon said, “on time and on budget.”
Financing good government must include a closer look at contractors, according to one labor leader. “If Congress is serious about saving money,” said Colleen M. Kelley, president of the National Treasury Employees Union, “lawmakers should look more closely at the contracting process.”
– by Joe Davidson – Washington Post – Friday, February 4, 2011; B03
In an about-face, the Army has suspended all of its ongoing insourcing activities, potentially savings thousands of private sector positions.
In a Feb. 1 memorandum, Army Secretary John McHugh announced he was halting the service’s insourcing initiative immediately in favor of a scaled-back approach in which his office would have to directly approve projects.
“In an era of significantly constrained resources, the Army must approach the insourcing of functions currently performed by contract in a well-reasoned, analytically based and systemic manner, consistent with law and prevailing presidential and Department of Defense guidance,” McHugh wrote in the memo, released on Thursday by the Professional Services Council, an industry group that has opposed plans to bring contractor jobs back in-house.
The memo suspends all ongoing insourcing transitions, but does not reverse efforts that already have been completed.
Army spokeswoman Anne Edgecomb said the memo is not intended to stop insourcing altogether but to ensure that the process is conducted responsibly and deliberately. “We are trying to make sure we do everything we can to be fiscally responsible,” Edgecomb said. “We see the writing on the wall.”
Edgecomb did not have figures immediately available on the number of contractor positions the policy change would effect.
The Defense Department’s insourcing program leader said on Thursday that the Pentagon did not direct Army to change its policy.
“The department is committed to meeting its statutory obligations under Title 10 to annually review its contracted services, identifying those that are inappropriately being performed by the private sector and should be insourced to government performance,” said Thomas Hessel, a senior manpower analyst in the Office of the Undersecretary of Defense for Personnel and Readiness, in a statement to Government Executive. “This includes services that are inherently governmental or closely associated with inherently governmental in nature; provide unauthorized personal services; or may otherwise be exempted from private sector performance … While some contracted services may be identified for insourcing, some services determined to be no longer required or of low priority may be eliminated or reduced in scope while others will continue to be provided by the private sector.”
All future insourcing proposals, McHugh wrote, must include “at minimum, a manpower requirements determination, an analysis of all potential alternatives to the establishment of permanent civilian authorizations to perform the contracted work, certification of fund availability and a comprehensive legal review.”
Thomas Lamont, assistant secretary of the Army for manpower and reserve affairs, along with Mary Sally Matiella, assistant secretary of the Army for financial management and comptroller, will be responsible for developing criteria to evaluate the efficiencies generated from the policy change, McHugh said.
Contractor groups, which have long criticized the Defense Department’s insourcing plans as driven by quotas and lacking any verifiable cost savings, applauded the development.
“Secretary McHugh is taking the right approach to insourcing,” PSC President Stan Soloway said. “We have said all along that all sourcing decisions for clearly commercial work — whether insourcing or outsourcing — must be done strategically with the best interests of the government mission and American taxpayer in mind.”
John Palatiello, president of the Business Coalition for Fair Competition, a group formed to challenge the Obama administration’s insourcing plans, said the memo is proof the initiative has been poorly executed.
“BCFC renews its call for a governmentwide moratorium on insourcing until common-sense standards and metrics for assuring that any insourcing is in the taxpayers’ interests, does not increase unemployment, and is focused on statutorily defined inherently governmental activities, not commercial activities,” Palatiello said.
The memo comes only a few weeks after the Government Accountability Office reported the Army had identified more than 4,200 full-time jobs in which contractors are performing either inherently governmental or unauthorized personal services. In both the inherently governmental and the unauthorized personal services contracts, the Army typically would be required to bring those functions back in-house.
Defense Secretary Robert Gates announced in August 2010 that the Pentagon was implementing a fiscal 2011 billet freeze and halting its insourcing plans because of a lack of cost savings. But, the plan affected only civilian agencies and offices. The military services were exempt from the freeze, allowing them to continue with their insourcing plans.
Soloway called on the other military services to follow the Army’s approach. “Through such a process the Army, DoD and the taxpayer will gain vital insight into the total life-cycle costs associated with these decisions, the degree to which they address the Army’s workforce needs, and more,” he said. “We hope, as they say, the Army leads the way.”
– by Robert Brodsky - GovExec.com - February 3, 2011
The Small Business Administration (SBA) has now released all the information needed for woman-owned small businesses to self-certify as eligible to participate in the federal government’s newest contract set-aside program.
The rules for the woman-owned small business (WOSB) contracting program were published in the Federal Register on Oct. 7, 2010. The rules are designed to get federal contracts to women-owned businesses in 83 industries. Specifically, the program allows contracting officers, for the first time, to set aside specific contracts for certified WOSBs and economically disadvantaged WOSBs to help federal agencies achieve the existing statutory goal of five percent of federal contracting dollars being awarded to WOSBs.
The rules allow WOSBs to either self-certify themselves as eligible to participate or secure certification through an approved third-party. While the SBA has not yet approved any third-party certifiers, WOSBs may now take steps to self-certify.
The Georgia Tech Procurement Assistance Center (GTPAC) recommends that you take these steps to qualify for the program:
- Familiarize yourself with the Compliance Guide for WOSB Program 02.2011.
- Determine whether your firm qualifies as a WOSB or an economically disadvantaged woman owned small business (EDWOSB), and then fill-out the appropriate certification forms: WOSB Certification Form – OMB Approved or EDWOSB Certification Form – OMB Approved. Be sure to assemble and compile all necessary documentation called for on the forms.
- Register in Central Contractor Registration (CCR) as a WOSB. (Note: Effective Feb. 22, 2011, CCR has added four new women-owned business types in support of the SBA WOSB program. These are: Women-Owned Small Business, Economically Disadvantaged Women-Owned Small Business, Joint Venture Women-Owned Small Business, and Joint Venture Economically Disadvantaged Women-Owned Small Business.) (Additional Note: CCR is currently experiencing a delay in processing new registrations and updates. If your renewal is affected, CCR will extend your expiration date by sixty (60) days. CCR is working to resolve the backlog by the end of March.)
- Register your WOSB status in Online Representations and Certifications Application (ORCA). (Note: Necessary changes in ORCA to allow for WOSB registration are not yet made; these changes are now estimated to be made in April 2011.)
- Establish an account in SBA’s General Login System so that you may upload your certification form and any documentation. You can familiarize yourself with the GLS by reviewing GLS Screen Shots – SBA WOSB Program – 02.2011, and you can set-up your account by clicking here.
The Georgia Tech Procurement Assistance Center will keep all clients advised on the implementation schedule for this important new federal program. If you need assistance, feel free to contact your nearest GTPAC Counselor.