Procurement

DOD to start filing more contract information

documentation

DOD contract documentation is about to become more exacting. (Stock image)

Defense contracting officers now must indicate the type of functions that service contracts cover, particularly those closely associated with inherently governmental or critical functions, as the data goes into the Federal Procurement Data System. The Defense Department is making the change to its practices because it handles work on contracts funded predominately by civilian agencies, according to a memo from Feb. 25.

Defense contracting officers have been spared the task for the past year, but that will change on March 1.

"This collection results in more information about the role service contracts play in achieving agency objectives," wrote Richard Ginman, director of defense procurement and acquisition policy, in a Feb. 25 memo.

Contracting officers must comply with the guidance issued in 2011 by the Office of Federal Procurement Policy. Gathering this data is a requirement included in the fiscal 2010 Consolidated Appropriations Act; Congress mandated the data from civilian agencies, but exempted DOD.

The appropriations law, however, applies to the funding organization. Since DOD works as the funding organization for many civilian agencies, DOD has decided to include the new reporting requirement for its employees. And while the new reporting starts March 1, Ginman told DOD contracting officers to do the designation of an earlier award if an agency requests it.

In the 2011 guidance, OFPP explained that the information would help agencies prioritize which contracts may need increased management attention to keep contractors away from inherently governmental functions while the agency maintains control of operations. Inherently governmental functions are jobs only federal employees are allowed to do.

The new data-gathering requirement is in addition to current DOD efforts. Defense contracting officials already are required to complete the DOD Inventory of Contracts for Services, and officials have decided to collect function indicators for DOD funded actions too. In addition, acquisition officers still must adhere to the guidance related to the Enterprise-wide Contractor Manpower Reporting Application. Officers also must continue including language about reporting all contractor labor hours in performance work statements for service contracts for or on behalf of the DOD, regardless of the funding source, Ginman wrote.

"Identifying closely associated and critical functions at the time of award should assist in prioritizing which contractors may require increased management attention and oversight to ensure that mission creep does not result in the performance of inherently governmental functions by contractors, and ensure that the agency does not lose control of its mission and operations," Ginman wrote.

About the Author

Matthew Weigelt is a freelance journalist who writes about acquisition and procurement.

FCW in Print

In the latest issue: Looking back on three decades of big stories in federal IT.

Featured

  • FCW @ 30 GPS

    FCW @ 30

    Since 1996, FCW has covered it all -- the major contracts, the disruptive technologies, the picayune scandals and the many, many people who make federal IT function. Here's a look back at six of the most significant stories.

  • Shutterstock image.

    A 'minibus' appropriations package could be in the cards

    A short-term funding bill is expected by Sept. 30 to keep the federal government operating through early December, but after that the options get more complicated.

  • Defense Secretary Ash Carter speaks at the TechCrunch Disrupt conference in San Francisco

    DOD launches new tech hub in Austin

    The DOD is opening a new Defense Innovation Unit Experimental office in Austin, Texas, while Congress debates legislation that could defund DIUx.

  • Shutterstock image.

    Merged IT modernization bill punts on funding

    A House panel approved a new IT modernization bill that appears poised to pass, but key funding questions are left for appropriators.

  • General Frost

    Army wants cyber capability everywhere

    The Army's cyber director said cyber, electronic warfare and information operations must be integrated into warfighters' doctrine and training.

  • Rising Star 2013

    Meet the 2016 Rising Stars

    FCW honors 30 early-career leaders in federal IT.

Reader comments

Sat, Mar 2, 2013 Jaime Gracia Washington, DC

Transparency is vital to understand how to improve buying, but more importantly, how to buy more strategically and save money without affecting mission outcomes. Service contract inventories, along with AcqStat reviews, should be analyzed to verify spend, innovate for strategic sourcing opportunities, shine the light on bad actors and improper "small business" awards to large primes while paving the way to limit inherently governmental contracts. One of the key methods will be big data analysis, along with standardizing FPDS inputs for consistence and accuracy, will go a long way towards improving contract spends and saving money, verifying impact, and also completing balanced workforce assessments for proper insourcing opportunities. Data drives decision making, or at least it should anyway.

Please post your comments here. Comments are moderated, so they may not appear immediately after submitting. We will not post comments that we consider abusive or off-topic.

Please type the letters/numbers you see above

More from 1105 Public Sector Media Group