The term 'critical function' becomes a little clearer

If your job helps drive the agency's mission, it might be a critical function.

If your job keeps the agency's IT infrastructure stable, it might be a critical function.

If your job supports the agency’s procurement office in awarding and managing contracts, it might be a critical function.

So what exactly is a “critical function”?

No one’s sure. For that reason, the term has concerned many people, especially government contractors. It was first used in March in a draft policy letter on the Obama administration’s insourcing program. Since then, some contractors have been wondering what the term means, whether the jobs they are doing are critical and whether they're going to lose those jobs.

The insourcing guidance describes the term this way:

“ ‘Critical function’ means a function that is necessary to the agency being able to effectively perform and maintain control of its mission and operations. A function that would not expose the agency to risk of mission failure if performed entirely by contractors is not a critical function.”

Last week, Dan Gordon, administrator of the Office of Federal Procurement Policy, said he has heard industry’s concerns about the term. And the final version of the policy letter, which should be released in early 2011, will shed some light on critical functions.

“We did actually name some examples,” Gordon said during a question-and-answer session after a panel discussion on Dec. 10. One example is work related closely to an agency’s mission. “Mission is usually critical.”

A second example is support operations. “We gave the two examples of IT and the contracting shop itself,” he said.

Without a clear definition of critical functions, industry leaders fear federal officials could easily find a reason why any function is critical to their agency’s operations. Experts have raised concerns that agency officials might use the term broadly to encompass too many jobs in the drive to insource work as they  try to rebalance a blend of federal employees and contractors.

Gordon doesn’t think agencies will abuse the term. But there’s another problem he sees.

“I will tell you, what’s more problematic is that people think if it’s critical, it’s got to be 100 percent federal,” he said. "And that is [emphatically] not what we're saying."

Gordon said OFPP's intent is for agency officials to make sure they have the capability internally to keep control of the critical function so they aren't overly reliant on contractors.

“There is no need to do massive insourcing, even in critical functions,” he said.

Posted by Matthew Weigelt on Dec 13, 2010 at 9:53 AM