Recently I wrote an article about the significant role that Contracting Officer’s Representatives (CORs) play in the acquisition process flow. In “Do COR’s Matter in Your Agency? Why they Should,” I advocated the importance of reassuring CORs that they are a valuable force within acquisition teams. This blog generated some really positive conversations, including with one reader whose agency has had the unique opportunity to build programs for CORs from the ground up.
“It is so true that this is an underappreciated, and often misunderstood, and almost always overworked group of people who are on the front lines of ensuring that money doesn’t leak out of government contracts,” says David Gragan, Senior Procurement Executive, Consumer Financial Protection Bureau (CFPB). He and his team shared with me four ways they believe their COR Certification Program has been successful.
Consumer Financial Protection Bureau
The CFPB was created by the Wall Street Reform and Consumer Protection Act about two years ago. Mr. Gragan and his team had the awesome opportunity to envision the kind of results they want, and to develop the COR Program and other agency policies that will get them there. In fact, this is a work in progress as they continue to develop agency guidance. CFPB’s budget supports an expected 1,214 full time equivalent employees in FY 2013 and 1,545 in FY 2014 to carry out the Bureau’s mission of marking markets for consumer financial products and services work for Americans.
The CFPB came into existence just as the Office of Federal Procurement Policy (OFPP) revised the COR Certification Program. In order to meet the revised training requirement, in-house training was established so the CORs would be compliant with the Certification changes. The CFPB COR population is less than 100, and is strategically formulated so that each Division has at least two trained CORs who are prepared to take the lead once appointed by the Contracting Officer (CO).
What Works for the CFPB COR?
The “Why Do CORs Matter” blog mentioned three possible remedies for such pitfalls as CORs juggling work between their assigned duties plus the ancillary COR responsibilities. Here’s how CFPB addresses the proposed remedies outlined in the blog.
Sharing knowledge and creating understanding across the department is key to successful outcomes, says Mr. Gragan. “We have heard a COR say, ‘You know, my boss doesn’t even know what I do.’ So, I thought, how can I help? I have a responsibility to ensure that your boss does know what you do.” CFPB carves out time for staff to meet and discuss roadblocks and solutions through:
- One-hour monthly round table meetings with CORs, COs, and staff members. These meetings provide opportunities for attendees to make presentations and/or guest speakers to discuss contract administration in general and COR duties specifically
- Quarterly newsletter is distributed to update staff on recent contract awards, how the procurement shop is doing, contract performance summaries for service contracts valued $150K, and round table meeting notes
From the beginning, CFPB created in-house training for its CORs. The challenge now is “to be innovative in our training,” says Mr. Gragan. Currently:
- Guest speakers from various segments of the Procurement profession attend the monthly round table meetings
- Training credit is granted to attendees for each in house event
- An annual agency Training Plan is being developed
- A Code of Ethics has been developed based upon information from National Contract Management Association (NCMA), National Institute of Governmental Purchasing (NIGP), and Institute for Supply Management (ISM) seminars. In addition to the annual ethics training that is mandatory for all employees, a special acquisition-related ethics training is held each year for the procurement workforce.
- All CORs are entered into the Federal Acquisition Institute Training Application System (FAITAS), a significant accomplishment which not all agencies have achieved
The importance of motivation in an organization can’t be overstated, and managers are tasked with finding creative ways to recognize and motivate staff. “It’s tougher now as managers because we don’t have tangible incentives that you can give folks, so it has to be intrinsic. It has to be motivational speaking and things like that,” says Mr. Gragan. “That is what we’re trying to do to make them feel like valuable members of our procurement team.”
- The CORs are constantly reminded that they are essential to the acquisition team verbally and through emails to them and their supervisors
- COR performance goals have been developed so that they may be included in individual performance plans to properly recognize the legitimacy and importance of the function
- CORs are highlighted as unsung heroes in agency presentations, such as at this weekend’s annual NIGP conference
- Planning is underway to start annual appreciation/meetings for the CORs
Contract Management Focus
The CFPB has made a conscious decision to focus its efforts on post-award management by regularly reviewing contractors’ performance on quality of service, business relations, timeliness of performance and cost control for all service contracts over $150,000.
In spite of the additional responsibility, there is a 100% COR compliance for this requirement. It helps the agency remain ahead of any potential management issues, and to develop annual performance assessments.
Given the chance to create a CORs Certification program from scratch, what is the CFPB doing right? Lots! The agency addresses continuous communication, encourages training, provides feedback, and focuses on the potential problematic piece of contract management – contractor performance monitoring.
What’s working in your organization?