This is sprinting season for any acquisition professional working on completing acquisition packages, negotiating offers and awarding the proposals. Contracting Officers (COs) should be proactive in doing all that needs to be done to ensure the requirements are awarded in a timely fashion.
While each agency has its own internal policies and regulations, there are some common must-do steps for both modifications on existing contracts and new requirements.
Modifications
Once funding has been approved on an existing contract, it is important to let the contractor know if the Government intends to exercise the option. Generally the timeframe is between 30 to 60 days. After this is done, the following documents are required, dependent upon your agency’s regulations:
- Prepare a memorandum to the CO explaining the parameters for the modification request (e.g. add items, exercise the option, delete Contract Line Items (CLINs), change the scope, etc.)
- Update the Market Research to ensure the incumbent contractor’s prices are still considered fair and reasonable
- Update the Independent Government Cost Estimate (IGCE) to prove that the incumbent’s awarded prices are still considered fair and reasonable
- If applicable, update past performance reports through the Contractor Performance Assessment Reporting (CPARs) or any other mechanism to validate contractor’s performance
- If applicable, update the Contracting Officer Representative’s (COR) information (this occurs if there is a change in either the COR or updated training for the current COR)
- Forward the completed acquisition package to the CO for final review and approval
New Requirements
Any new requirement should be submitted prior to the agency’s publicized “cut-off” date, which is usually between June and August of the fiscal year (FY). Any new requirements after this date must be approved by several layers (both Finance and Acquisition) within the organization. It is possible that some will be funded and others will not.
Here are some suggested documents needed for new requirements:
- Approved funding document
- Acquisition Plan based upon the dollar amount of the requirement
- Market Research
- Analysis of appropriate contract vehicle for the requirement based on market research and acquisition plan, including but not limited to GSA Alliant, NITAAC, NASA SEWP, EAGLES II, TABSS, and GSA Federal Supply Schedules
- IGCE comparing at least three contractors’ pricing based on the market research and the contract vehicle to be used
- Memorandum to the CO explaining the new requirement and the period of performance, if applicable
- Once completed, submit the acquisition package to the CO for review and final approval
Unfunded Requirements (UFRs)
These are the unplanned requirements that appear unexpectedly. The finance, acquisition and program office parties must meet to discuss if any of these UFRs will be funded. Depending upon the circumstances, the approved UFRs will be treated as either a modification or new requirement.
Why Time is of the Essence
This is the most critical time for the acquisition cycle because the Government is nearing the end of the fiscal year. With fewer than 30 business days remaining, there are many steps to complete in a condensed window of time. The luxury of a 30-45 day review cycle must now be condensed. Although the review time is reduced, it is imperative that quality checks are performed on the documents before forwarding to the CO for signature. Once reviewed and approved, the documents must be uploaded into the contract writing system approved by your agency.
Remember, last minute rushes may result in lower-quality acquisition packages which could cause undue delays with the final procurement process. It is imperative that the last-minute requirements are not only approved but carefully researched to ensure that the requirement’s price is fair and reasonable, and purchased not only from the correct contract vehicle but with small businesses in mind first.
Cross the Finish Line
Always remind yourself of the significance of meeting the impending deadline and how if the requirements are not completed by the end of the fiscal year, there will be a negative impact on the organization and its ability to meet its mission… Proactive COs and CORs are the key to finishing the race.
So, prepare all necessary documents depending upon modification or new requirement. If compelling and urgent after the Official Cut Off as outlined by your specific agency acquisition policy and/or finance make sure you perform adequate quality checks for all documents to ensure accuracy and completeness. Finally, make sure that the CO has all documents needed to review and award the acquisition package in a timely manner. Following these steps will lead to in-time award of requirements.
