Attachment 1 - APU 26-01.pdf

Treasury Common Services Center (TCSC) Operational Acquisition Procedures Directive No. 26-01

February 25, 2026

TREASURY COMMON SERVICES CENTER

Washington, D.C.

MEMORANDUM FOR BUREAU CHIEF PROCUREMENT OFFICERS

FROM: Alan J. Monico Jr., Interim Associate Administrator for Acquisition Services

SUBJECT: Direction for Implementing APU 26-01 Mandatory Staffing Plan Requirements

1. Purpose: This memorandum provides procedural direction to Contracting Officers (COs) and Bureau Chief Procurement Officers (BCPOs) for the implementation of Acquisition Procedures Update (APU) No. 26-01. APU 26-01 requires the inclusion of a staffing plan and a monthly workforce report for all (active and upcoming) service acquisitions set aside under the Revolutionary Federal Acquisition Regulations Overhaul (RFO) Part 19 Small Business except for contracts expiring within 30 days of this memorandum. This guidance is intended to ensure consistent, timely, and enforceable implementation across Treasury bureaus.

2. Key Actions:

• New and Existing Solicitations and Awards: Effective immediately, all new and existing solicitations and awards are subject to APU 26-01 shall include the Monthly Workforce Report Post Award Contract Deliverable (Attachment 2 to APU 26-01) as a recurring deliverable.

• Due Date for Contract Modifications: Bureaus shall complete all required contract modifications within 60 calendar days of the effective date of this directive.

• Integration with Invoice Processing Platform, (IPP): The contractor shall submit each deliverable as an attachment to an invoice or as a standalone document through the Invoice Processing Platform (IPP). Only in rare cases where the Contractor is not required to use the IPP, the CO shall receive Chief Procurement Officer approval in writing (retained for the contract file) to direct through the modification that the contractor send the monthly deliverable directly to the CO and Contracting Officer Representative (COR) marked with “CUI//SP-

PRVCY.”

• Expiring Contracts: Contracts expiring within 30 days of the effective date of this directive are exempt from the requirements of APU 26-01.

3. BCPO Required Actions:

• BCPOs are responsible for oversight and compliance to ensure COs and COR are informed of these requirements as discussed herein and that contract modifications reflect appropriate incorporation, administration, and enforcement.

• BCPOs are directed to immediately begin modifying existing applicable awards for service contracts awarded under FAR Part 19 set-aside authorities to incorporate the APU 26-01 requirements.

• BCPOs shall assign a Project Manager (PM) to work with TCSC Acquisition Services to oversee and expedite bureau launch, initial, and weekly progress of actions as a result of APU 26-01.

Romeo Merenov (Romeo.Merenov@treasury.gov) is the TCSC Acquisition Services Point of Contact (POC).

• BCPOs shall prioritize award modifications in descending order of total contract dollar value, focusing first on higher-dollar value contracts and ordering vehicles with significant remaining periods of performance.

• Weekly progress reporting is required for 60 days or until confirmation of 100% modifications has been completed. The PM or designee is responsible for submission of weekly reports. BCPOs shall provide an email each Friday NLT 2PM EST to TCSCAcquisitionServices@treasury.gov indicating the number of completed modifications. Modifications are not complete until reported in FPDS.

• Modifications shall add the Monthly Workforce Report Post-Award Contract Deliverable (Attachment 2 to APU 26-01) as a required recurring monthly deliverable for the duration of the contract exactly as it appears in the APU. The report is due as an attachment to submission of the monthly invoice.

• Submission is required monthly regardless of the award’s actual billing cycle.

• The deliverable shall be submitted in PDF format, including the signed certification statement, and must contain all data of the Monthly Workforce Report Post-Award Contract Deliverable (Attachment 2 to APU 26-01) and must include the complete and accurate contract number, contractor name and Unique Entity Identification (UEI) number.

• BCPOs are required to review the monthly report (attachment 2) and ensure compliance prior to reviewing and approving the monthly invoice.

• BCPOs shall ensure that for applicable service contracts except for construction each monthly workforce report includes a certification signed by an authorized company officer affirming, based on current performance data, the small business prime and its similarly situated subcontractors, collectively performed at least 51 percent of the total contract cost for personnel during the reporting period; for construction contracts the percentage is 15 percent; and for special trade contracts the percentage is 25%.

• Contractors shall submit one report per contract, aggregated across all subcontractors.

• BCPO shall ensure Contractors limit the monthly report to the fields specified in the mailto:(Romeo.Merenov@treasury.gov template; do not include SSNs, dates of birth, home addresses, or other unnecessary PII.

Reports containing PII must be encrypted, access-controlled, and transmitted via approved secure channels. Mark files “CUI//SP- PRVCY.” Limit distribution of files with PII to the Chief Operating Officer, Chief Financial Officer, CO, COR, and designated security and human resources officials.

• BCPOs shall ensure any suspected or confirmed security breach must be reported immediately to the CO and agency privacy/security officials in accordance with OMB Memorandum M-17-12 and bureau procedures.

4. CO Required Actions:

• COs shall incorporate the requirements of APU 26-01 using the appropriate contract sections, clauses, attachments, schedules, or ordering provisions, consistent with the contract type and vehicle being modified.

• For audit purposes, the modification for the requirements of APU 26-01 must be issued as a stand-alone bi-lateral modification. It may not be combined with other contract modification requirements.

• The CO shall utilize the following language in each modification to incorporate APU 26-01 into each contract/order:

“The purpose of this modification is to incorporate the requirements of Acquisition Procedures Update (APU) No. 26-01, Mandatory Staffing Plan and Monthly Contractor Workforce Reporting Deliverables (attached) for this contract/order.

This contract/order is modified to add the three attachments below in Section J (or equivalent) and to require contractor compliance with APU 26-01 in its entirety. The Contractor shall provide an initial staffing plan within 30 days of the issuance of this modification.”

Attachment 1 – Initial Staffing Plan Required Template Attachment 2 – Monthly Workforce Report Required Template Attachment 3 – APU 26-01

The Contractor shall return signed modification within 5 business days from date of issue of this modification.

• To incorporate APU 26-01the CO shall insert the following in the instructions to offerors in each solicitation:

Offerors are required to comply with Treasury APU 26-01(attached to this solicitation) in its’ entirety. The Initial Staffing Plan (APU 26-01attachment 1) must be included with your submission. Upon award, the Monthly Workforce Report (APU 26-01 Attachment 2) is required to be submitted with your monthly invoice; however, submission is required monthly regardless of the award’s actual billing cycle.

• For all solicitations for services and the resulting contract or order, the CO shall include the mandatory deliverable templates shown in Attachments 1 and 2 of this directive.

• Solicitations shall require offerors submit an initial staffing plan using the template attached to this document (Attachment 1) as part of their technical proposal. The plan shall reflect the proposed labor mix for the base and each option period and identify prime and subcontractor roles.

• The CO shall ensure the offerors staffing plan includes a clear breakdown of prime versus subcontractor labor hours and cost by labor category for the base and each option period. This information shall be utilized by the CO to verify compliance at award

• The CO shall utilize the monthly workforce report and attached company certification to verify

Contractor compliance throughout performance of the contract

• COs shall ensure compliance of receipt and acceptance of contract deliverables.

• COs shall ensure the initial staffing plan templates and reporting requirements are clearly identified in the contract in a manner appropriate to the contract structure.

• The CO shall ensure offerors certify in their initial staffing plan that the small business prime contractor will perform at least 51 percent of the cost of contract performance incurred for personnel with its own employees or those of other similarly situated small business concerns.

o If the deliverable is incomplete (or uncertified), regular remedies apply.

• COs shall ensure CORs are instructed to review the workforce report attachment as part of standard receipt and acceptance procedures. Deliverables either unsigned or omitting any elements from the Monthly Workforce Report Post-Award Contract Deliverable (Attachment 2 to APU 26-01) shall be considered deficient. As a required contract deliverable, all standard requirements applicable to contract deliverables—including timeliness, accuracy, and acceptance apply.

o If the deliverable shows subcontracting in excess of 50%, The CO should raise this to the attention of the bureau project manager and bureau chief procurement officer. The BCPO or delegee will contact the SB principal to discuss and possible remediate.

• To ensure Federal Procurement Data System (FPDS) reporting, COs shall include the exact phrase “Monthly Workforce Report” within the FPDS Description of Requirement field so that this data may be easily aggregated and simplify compliance reporting.

5. Point of Contact: Romeo.Merenov@treasury.gov

6. Attachments:

Attachment 1: Required Template -Initial Staffing Plan (Proposal Deliverable) Attachment 2: Required Template - Monthly Workforce Report (Post-Award Contract Deliverable) mailto:Romeo.Merenov@treasury.gov

Attachment 1 – Initial Staffing Plan (Proposal Deliverable) Offerors shall complete and certify the table below for the base and each option period

Vendor Name Solicitation/Contract Number .

Level of Effort (LoE) may be expressed in hours or FTEs, as specified by the solicitation.

Mark “CUI//SP-PRVCY.”

Line

Period of Performance

Employer Company

Labor Category

Labor Type (Technic al/Non- Technica l)

Employee Last Name

Employee First Name

PIV /

Employe e Unique ID (must provide NLT first Monthly Report)

Estimated LoE (Hours or FTEs)

Work Locati on (On/O ff site)

Employee Work Email Address

Employee Work Phone Number

Employee Complete Work Address with Zip code

Attachment 2 – Monthly Workforce Report (Post-Award Contract Deliverable)

Contractors shall submit one report as an attachment to the monthly invoice per contract/order, aggregated across all subcontractors. “CUI//SP-PRVCY.”

Instructions: Contractors shall include with each monthly workforce report a certification signed by an authorized company officer affirming that, based on current performance data, the small business prime and its similarly situated subcontractors collectively performed at least 51 percent of the total contract cost for personnel during the reporting period; for construction contracts the percentage is 15 percent; and for special trade contracts the percentage is 25%. This information shall be used by the CO to verify compliance throughout performance

Required Contractor Unique Entity Identification (UEI) Number:

Company Name Required Contract number (PIID):

Required: Signature of Authorized Company Official

Line

Billing Period Start and End Dates

Employer Company

Labor Category

Labor Type (Technical / Non- Technical)

Employee Name (Last name, first name)

PIV No.

(Unique

ID)

Work Status (F/T, P/T)

Hours Worke d (Billing Period)

Work Location (On/Offsite)

Start/End Date on Contract

Employee Work Email Address

Employee Work Phone Number

Employee Complete Work Address with Zip code