OMB's revised A-76 is nearly ready

'It is a lot cleaner and a lot clearer. We spent a lot of time on the language and the words, making it understandable for everyone.'

'Angela Styles, Administrator of the Office of Federal Procurement Policy

Henrik G. DeGyor

A pilot phase of the revised OMB Circular A-76 will likely involve IT functions, procurement czar Angela Styles said last week.

The Office of Management and Budget expects within a few weeks to release the revised circular for public comment, said Styles, administrator of the Office of Federal Procurement Policy. The chief change: It will incorporate the best-value approach required by the Federal Acquisition Regulation.

To test it, OMB will have agencies use it for a select set of procurements, said Styles, who spoke at a Heritage Foundation luncheon in Washington.

OMB has not set a deadline for the final release of the circular, which guides agencies in deciding whether to continue a job within the government or outsource it. The Bush administration has a goal of competitively sourcing 15 percent of noninherently governmental jobs by October 2003.

OFPP officials consider IT programs ideal for testing the revised circular.

'I can't imagine an industry that is more appropriate for not just looking at the low-cost provider, which is what our current circular is based on right now,' Styles said. 'We want it to be a true cost-technical trade-off.'

Although OFPP is unsure how long the pilot phase will last, it will be open to all civilian agencies. The Defense Department is excluded because Congress mandated 20 years ago that DOD use low cost as the key criterion in its A-76 reviews.

When the circular is published, it will be pared down to about 50 pages from 120, including a two-page policy guidance and six appendices covering topics such as compiling agency job inventories, a seven-step public-private competition process, interagency service support and cost issues, Styles said.

'We are trying to make sure it is not an amorphous mess that you have to be a specialist to understand and walk through,' said Styles, who added that she has spent about four hours a day since May working on the revision. 'It is pretty close to that. It is a lot cleaner and a lot clearer. We spent a lot of time on the language and the words, making it understandable for everyone.'

OFPP is incorporating many of the suggestions of the Commercial Activities Panel. The congressionally mandated group in April released its recommendations on how to improve the A-76 process.

Among the two most significant changes to the circular will be the introduction of the integrated acquisition process and OMB's recommendation that two separate teams write the statement of work and the proposal, Styles said.

A major change in the new integrated process is that government teams no longer will be guaranteed a place among the finalists of a competition, Styles said. Under the current A-76 process, agencies review vendors' bids and then compare the winning vendor submission against the government teams' proposals.

'The best person providing the service will win, and we will treat everyone on a level playing field for purposes of competition,' she said. 'This is like source selection in the FAR, and this is the most fundamental change in the circular.'

Cover all the shots

The process will offer protections to make sure government employees have a fair shot at retaining the work, Styles said.

'Everyone will be thrown in the pot in the beginning to assess the technical value of the proposal,' she said. 'When you have one company that proposes more than what we are asking for, we will go back and ask for more proposals from everyone, which is probably how the process should work.'

She said OMB officials intend to make sure that agencies have the resources and training to compete.

Styles said by separating the teams that write the statements of work and that put together the government's bids, the circular will eliminate concerns about conflicts of interest.

'We are recommending a single point of contact for each of the two functions,' she said. 'It could be one office or more than one depending on the agency, but having separate teams will make the competition fairer.'

The revision also will let agencies keep savings realized from A-76 competitions.

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