W911SA-19-Q-3029_Attachment_2_Drawing_CA012.pdf

It’s October…..We’ve made it through another fiscal year end and although it’s tempting to kick back and relax a little, it’s time to shift the focus to con-tract administration and ensuring that our customers get what they paid for.

Contract Administration, also referred to as Contract Management, encom-passes all the interaction between the Government and the contractor from the time the contract is awarded until the work has been completed and accepted, all payments have been made, excess funds are de-obligated, and all disputes resolved.

The best way to ensure contract success is to plan for it. A Contract Admin-istration Plan addresses the activities to be performed by the Government in managing and administering a contract. To be effective, a Contract Admin-istration Plan should include, at a minimum:

Contract Summary and Scope of Work to include the type of work being performed, place of performance, period of performance, total value and significant features of the contract

Key Personnel - both Government and Contractor, including roles, respon-sibilities, authorities, and limitations

Contract transition plan including transition strategies, schedules and re-sponsible parties required to facilitate transition

Communication plan that defines modes and methods of communicating information and direction to the contractor, procedures for problem identi-fication and resolution

Required work products/deliverables and delivery schedule

Methods for conducting quality inspections, assessments, evaluations to include reference to the contractor’s Quality Control Plan (QCP) and the Government’s Quality Assurance Surveillance Plan (QASP)

Payment procedures for reviewing invoices and authorizing payments

Contracting Operations Bulletin

1 0 O C T O B E R 2 0 1 8

Purpose: The purpose of this publication is to pro-vide field office staff within the Mission and Installa-tion Contracting Com-mand with timely infor-mation and updates from the Contracting Opera-tions Directorate. This information is for

MICC only and is not to be forwarded to other Commands or

Customers.

Mission and Installation Contracting Command

It’s Awarded, Now You Have to Administer It—

Contract Administration Plans

Mission: The MICC pro-vides Army commands, installations, and activities with disciplined and re-sponsive contracting solu-tions and oversight. On order, provides trained and deployable Contract-ing Support brigades to the Operating Force.

Vision: We do the right thing every day and are known as the Army’s premier contracting organ-ization.

P A G E 2

C O N T R A C T I N G O P E R A T I O N S B U L L E T I N

Contract Administration Plans (Cont)

Contract modification procedures

Description of the option exercise process that ensures sufficient lead time to process the option modifica-tion, or take action to award an alternative contract.

Description of Government Furnished services, items, property, or information identified in the contract and identity of individual(s) accountable

Record keeping responsibilities of the office responsible for contract administration to ensure the closeout process is not unduly delayed because of missing documentation.

And as applicable:

Award Fee Administration processes Earned Value Management reporting requirements Any delegated contract administration services and the office that received the delegation Any known significant contract vulnerabilities or performance risks and the individuals responsible for mitigating these risks.

Ideally, the Contract Administration Plan should be addressed early in the acquisition strategy phase of the procurement cycle. But if that does not occur, a thorough Contract Administration Plan can still be created later in the acquisition process. The Contract Administration Plan should be a product of the entire contract management team. All of the members of the team, including the contracting officer and contract specialist, project or program manager, COR(s), technical lead(s), financial leads, property administrators, security man-agers should have input into the plan and should know the process for modifying the plan when necessary.

To help get you started with creating a plan, the Virtual Acquisition Office (VAO) has several excellent tem-plates that can be used to develop a contract administration plan tailored to your specific acquisition. They can be found at these following links: Link 1, Link 2, and Link 3. Remember you must log into VAO to ac-cess these templates.

Independent Government Cost Estimates (IGCEs)

IGCEs continue to be an area of systemic weakness across the MICC. Procurement Management Reviews in FY18 confirmed that many offices still struggle to comply with elements of the IGCE outlined by AFARS

5107.90. One of the toolkits used as part of the PMR process, the Contract Execution Toolkit (CET), has three questions related to IGCEs:

1. ARMY-00050 Is there an Independent Government Cost Estimate (IGCE) in the official contract file for procurements over the Simplified Acquisition Threshold (SAT)?

2. ARMY-00060 Was the Independent Government Cost Estimate (IGCE) developed with enough detail to verify the validity of the contractor's proposal and include sufficient narrative and detail to include reference material to support its preparation?

3. ARMY-00070 Does the Independent Government Cost Estimate (IGCE) include the required sig-natures (preparer and preparer's supervisor) and certification that the IGCE/IGE was developed inde-pendently by the Government prior to seeking any formal proposals from contractors?

https://micc.aep.army.mil/COP/PG/Acquisition%20Instructions%20%20MICC/MICC%20Contracting%20Operations%20Bulletin/Contract%20Ops%20Bulletin%20Documents/VAO%20contract%20admin%20plan%20simplified%20.doc https://micc.aep.army.mil/COP/PG/Acquisition%20Instructions%20%20MICC/MICC%20Contracting%20Operations%20Bulletin/Contract%20Ops%20Bulletin%20Documents/VAO%20Contract%20Admin%20Plan.docx https://micc.aep.army.mil/COP/PG/Acquisition%20Instructions%20%20MICC/MICC%20Contracting%20Operations%20Bulletin/Contract%20Ops%20Bulletin%20Documents/VAO%20contract%20management%20plan.docx

P A G E 3

Independent Government Cost Estimates (IGCEs) (Cont)

In order to comply with these three questions, contracting personnel must ensure the requirements of AFARS

5107.9002 are present:

1. Have an IGCE in the contract file for all procurement actions in excess of the simplified acquisition threshold (SAT), and if required by the KO, include and IGCE for actions less than the SAT.

2. Prior to accepting an IGCE, ensure that:

The IGCE contains enough detail to verify the validity of the offerors’ proposals;

The IGCE provides sufficient narrative and analytical detail, to include reference material, to support its preparation;

The preparer reviews, signs by hand or by Common-Access-Card and dates the IGCE, and includes the preparer’s organization, position, title and telephone number;

The preparer’s immediate supervisor reviews, signs by hand or by Common-Access-Card and dates the IGCE, and includes the reviewer’s organization, position, title, rank or grade and telephone number; and

The IGCE includes a signed, by hand or by Common-Access-Card, certification that the Government independently developed the IGCE—

Prior to seeking any formal proposals from contractors; or

For construction, within a timeframe consistent with FAR 36.203.

Requiring Activities are responsible for developing the IGCE. To assist with that preparation, our command has the MICC IGCE Guide and the GSA Acquisition Gateway also provides an IGCE Creation Tool. Please share these resources with your requiring activities to help them improve the quality of their IGCEs, which will in turn assist your office with better compliance with AFARS 5107.9002.

Virtual Acquisition Office—FREE Webinars

VAO is presenting 2 free webinars:

“Acquisition Update: A Look at September” on Thurs-day, 11 Oct 18 from 12:00p to 1:00p (Eastern time) to discuss: Who has funding set for fiscal 2019, and whose financial fate will be decided by lawmakers after midterm elections? Problems that continue to plague the acquisition workforce year after year—and what you can do to flip the script, Tech check: machines soon to start lending a hand, Pro tips and things to think about for successful emergency contracting

“Keys to Successful Proposal Evaluation” on Thursday, 18 Oct 18 from 12:00p—1:00p (Eastern time) to dis-cuss tips and best practices on how to evaluate competitive proposals under FAR 15 that will help to keep you out of trouble. Topics will include: Conduct an LPTA vs a tradeoff evaluation, Evaluate quality as a standalone or embedded factor, Evaluate risk and past performance, Align requirements and evaluation fac-tors to proposal responses, and Use oral presentations effectively.

If you are unable to attend the live webinar, visit the "My CLPs" page on VAO to access the recorded event.

http://farsite.hill.af.mil/vmafara.htm http://farsite.hill.af.mil/vmafara.htm https://micc.aep.army.mil/COP/AP/Acquisition%20Processes%20Library/Cost%20and%20Price/IGCE%20Guide%20-%20JUN%202016.docx https://interact.gsa.gov/blog/creating-government-cost-estimates-acquisition-gateway https://www.gotovao.com/?authkey=30586CE092740FC06C54FA52ED3BB96232064115&action=comment&id=0390067627000443&utm_source=webinar&utm_medium=email&utm_campaign=Oct11Update https://www.gotovao.com/?authkey=30586CE092740FC06C54FA52ED3BB96232064115&action=comment&id=0390049914000443%20&utm_source=webinar&utm_medium=email&utm_campaign=successfulproposaleval

P A G E 4

Selecting Product Service Codes – A Better Way!

Contract Action Report (CAR) data are used to create recurring and special reports to the President, Congress, Government Accountability Office, Federal executive agencies, and the general public. The data are also used to populate the USAspending.gov website in accordance with the Federal Funding Accountability and Trans-parency Act. Therefore, it is extremely important that Requiring Activities (“customers”) (via purchase re-quests) and contracting personnel enter data that are accurate and complete in accordance with FAR 4.604.

FSCPSC.com is a Product Service Code (PSC) prediction service developed by the Naval Postgraduate School and the Air Force Installation Contracting Agency to improve efficiency and consistency in selecting PSCs. Currently, acquisition personnel classify product and service requirements into one of several thousand possible PSCs. This is a tedious, time-consuming process that, for many areas of spend, tends to lead to incon-sistent classification due to its subjective nature. FSCPSC.com employs machine classification of acquisition requirements (i.e., a machine learning implementation) to facilitate proper PSC coding as well as North Amer-ican Industry Classification System (NAICS) coding.

The website is easy to use - simply enter free text descriptors of the supply/service requirement and the web-site will return a selection of possible PSCs/FSCs. FSCPSC.com uses machine learning enabling the website to return more accurate results as users provide more feedback, such as whether or not the search results were accurate. The search results are also grouped by a "Match Quality" indicator measured in percentage - the higher the percentage the likelier that the match is more accurate. In addition, by selecting the “More Info” tab, users are presented with the best possible NAICS matches.

Use of the website should help the data integrity of FSC/PSC entries on MICC’s CARs. However, since our requiring activities generate FSC/PSC coding (via GFEBS Purchase Requests (PRs)) it's imperative that we notify our requiring activities about the FSCPSC.com website to facilitate accurate PR coding. Please take a few minutes to share this helpful website with your respective requiring activities. By increasing the use of FSCPSC.com, we will all contribute to a better way to improve data integrity.

For additional information regarding FSCPSC.com, contact John Campos in the MICC HQ Business Intelli-gence branch at john.e.campos.civ@mail.mil .

Got Desk Book Questions or Suggestions? Submit Here

MICC HQ Acquisition Policy & Oversight (AP&O) recently launched a new link on the MICC SharePoint site for MICC contracting personnel to submit questions regarding the MICC Desk Book or suggestions for improvement to the MICC Desk Book. This new link will allow submission of the question or suggestion and allow AP&O staff to provide a written, trackable response to the submission. Responses will be posted quar-terly on the MICC SharePoint site.

https://www.fscpsc.com/ https://micc.aep.army.mil/pages/home.aspx

P A G E 5

SAM Exclusions Checks-

Still Required and Still a Command Weakness Failure to conduct checks of the SAM Exclusions is still being identified as a recurring weakness during Procure-ment Management Reviews (PMRs). There are two main causes: 1) failure to check SAM Exclusions at the times as required by FAR 9.405 and AFARS 5109.405(d)(1), and 2)failure to properly document Paperless Contract

Files (PCF) with results of the verification checks.

As we start a new fiscal year, the following information is provided as a reminder on the SAM Exclusion require-ments. In order to be in complete compliance, KOs shall ensure that SAM Exclusions are checked at least twice and ensure that results are documented in the contract file.

st

SAM Exclusion Check:

Prior to issuing a solicitation on a sole source basis

Prior to solicitation under IDIQs (MATOC)

After opening of bids or receipt of proposals nd

SAM Exclusion Check:

Prior to award of a new contract Prior to placement of a new purchase or task or delivery order

Prior to exercise of an option

Prior to award of any modification that adds new work or extends the duration of the contract or the period of performance

Prior to consent to subcontract

The FAR 9.405(d)(4) requires the 2nd SAM Exclusion check to be “immediately” prior to award. For purposes of the Procurement Management Reviews, DASA(P) has allowed flexibility to define “immediately” as 24 hours pri-or to award, in order to be in compliance.

Document the contract file:

AFARS 5109.405(d)(1) requires contracting officers to maintain a copy of the results of the reviews in the contract file. Therefore, KOs must ensure the PCF contract file is properly documented with actual print outs of SAM Ex-clusion checks. The print outs provide proof of the date the check was performed.

SAM Exclusion checks are required for simplified acquisitions valued at or below the Simplified Acquisition

Threshold (SAT). As stated in the MICC Desk Book 5109.405(200)d., placing a check mark in the boxes under section 12, Contractor Responsibility Determination, of the Simplified Acquisition Price Analysis and Award

Memorandum (SAPAAM) template DOES NOT eliminate the requirement to document the review of the SAM

Exclusions in PCF. Print outs of the review are to be placed in PCF contract file.

If for any reason the SAM website is down, the contract file must be documented explaining the situation. SAM

Exclusions shall then be checked and documented in the contract file as soon as the website becomes available.

It is the responsibility of the KO to ensure that government contracts are awarded only to eligible contractors. Part of that responsibility includes the mandatory SAM Exclusion checks. In order to protect the government, KOs shall take time to conduct proper SAM Exclusions checks and to document the official contract file properly.

For more information, refer to MICC Desk Book, 5109.405 Effect of Listing.

P A G E 6

PARC Policy Alerts

PARC Policy Alert 18-115 and Revision 1, Emergency Declaration Approved In Response to Hurricane Florence, was issued on 12 and 13 Sep 18 respectively, is to announce the Presidential approval of an emer-gency declaration, effective 10 Sep 18, under the authority of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5121 et seq. (the "Stafford Act") for North Carolina and South Carolina in response to Hurricane Florence. Please see www.fema.gov/disasters for specific information on the emer-gency declaration. Revision 1 updated the emergency declaration, effective 11 Sep 18, for Virginia in re-sponse to Hurricane Florence. The increased thresholds and acquisition flexibilities initially authorized in the 11 Sep 18 DPC information release entitled "Emergency Declaration for Hurricane Florence" can be applied to relief operations in Virginia and any additional state that is declared an emergency or major disaster by the President hereafter in response to Hurricane Florence.

PARC Policy Alert 18-116 Hurricane Florence-Limited Exemption and Waiver from Certain Federal Contracting FAR Requirements, was issued on 19 Sep 18 to inform the contracting workforce of special circumstances regarding Hurricane Florence. The U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) has granted a limited exemption and waiver from certain federal contracting Federal Acquisition Regulation (FAR) requirements. The Hurricane Florence exemption and waiver period is granted from 17 Sep 18 to 14 Dec 18, subject to extension by OFCCP.

PARC Policy Alert 18-117, PEOs Delegated MDA for Urgent Capability Requirements, was released on 19 Sep 18 to provide authority to Program Executive Officers as the Milestone Decision Authority for Urgent Capability Requirements that can be fielded in less than two years and are below Acquisition Category (ACAT) I cost thresholds.

PARC Policy Alert 18-118, Contractor’s Common Access Cards (CACs), was issued on 21 Sep 18 to an-nounce a reminder from US Army Human Resources Command that CACs may be issued for a period not to exceed 3 years from the date of issuance in accordance with referenced memorandum and regulations, and that Contracting Officers will continue to consider the specific contract and contract length in determining CAC eligibility.

PARC Policy Alert 18-119, Class Deviation 2018-O0020 - Permanent Supply Chain Risk Management Authority, was issued on 24 Sep 18 and became effective immediately. This class deviation removes the sun-set date at DFARS 239.7300(b) and changes the statutory citations in DFARS subpart 239.73 from section 806 Pub. L. 111-383 to 10 U.S.C. 2339a. Contracting officers shall use the provision and clause provided in the attachment to this deviation in lieu of the provision at DFARS 252.225-7017, Notice of Supply Chain Risk, and clause at 252.225-7018, Supply Chain Risk, as prescribed in the attachment.

PARC Policy Alert 18-120, Organizational Name Change to Defense Pricing and Contracting, was is-sued on 24 Sep 18 and became effectively immediately. The organization formerly known as Defense Pric-ing/Defense Procurement and Acquisition Policy (DP/DPAP), has been renamed as Defense Pricing and Con-tracting (DPC).

Policy Alert 18-121, ASA(ALT) Strategic Approach to Lead Time, was issued on 25 Sep 18, to announce an ASAALT Memorandum (see Reference 2) to define the ASA(ALT) strategic approach to lead time and provide guidance for implementation of directives for use of the tools in the Virtual Contracting enterprise (VCE) [see Reference 1].

PARC Policy Alert 18-122, System for Award Management Registration (FAR Case 2015-005), was is-sued on 30 Sep 18 and becomes effective 26 Oct 18. DoD, GSA and NASA are issuing a final rule amending the FAR to update the instructions for registration in the System for Award Management and clarify the tim-https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-115%20Rev%201%20Emergency%20Declaration%20Approved%20In%20Response%20to%20Hurricane%20Florence%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-115%20Emergency%20Declaration%20Approved%20In%20Response%20to%20Hurricane%20Florence%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-115%20Emergency%20Declaration%20Approved%20In%20Response%20to%20Hurricane%20Florence%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-115%20Rev%201%20Emergency%20Declaration%20Approved%20In%20Response%20to%20Hurricane%20Florence%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-116%20Hurricane%20Florence-Limited%20Exemption%20and%20Waiver%20from%20FAR%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-116%20Hurricane%20Florence-Limited%20Exemption%20and%20Waiver%20from%20FAR%20JCourtis.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-117%20PEO%20Designated%20as%20the%20MDA%20for%20Urgent%20Capability%20Requirements%20GFoley.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-118%20Contractors%20Common%20Access%20Cards%20MCawthorne.msg https://www.acq.osd.mil/dpap/policy/policyvault/USA002323-18-DPC.pdf https://www.acq.osd.mil/dpap/policy/policyvault/USA002323-18-DPC.pdf https://www.acq.osd.mil/dpap/policy/policyvault/USA002025-18-DPC.pdf https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-107%20Guidance%20on%20Annual%20CTIP%20Training%20KBuehler.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2018-121%20ASAALT%20Strategic%20Approach%20to%20Lead%20Time%20LCloutier.msg https://www.gpo.gov/fdsys/pkg/FR-2018-09-26/pdf/2018-20706.pdf

P A G E 7

PARC Policy Alerts (Continued) ing of registration in the System for Award Management. Additional changes to AFARS 5109 are forthcom-ing.

PARC Policy Alert 18-123, One Dollar Coins (FAR Case 2018-009). was issued on 30 Sep 18 and becomes 26 Oct 18. DoD, GSA and NASA are issuing a final rule amending the FAR to implement section 104 of the FY18 NDAA that provides an exception for business operations conducted by a contractor while performing under a Government contract from the requirement to accept and dispense $1 coins.

PARC Policy Alert 18-124, Repeal of DFARS Clause "Additional Services" (DFARS Case 2018-D027), was issued on 30 Sep 18 and became effective 28 Sep 18. DoD issued this final rule amending the DFARS to remove a clause that is outdated and no longer used. The removed clause is DFARS clause 252.247–7020, Additional Services, and the associated clause prescription at DFARS 247.271–3. DFARS clause 252.247– 7020 applies to personal property movement and storage contracts when a need for services related to the con-tract, but not specifically addressed in the contract, occurs during contract performance. This deletion is in support of the recommendations of the DoD Regulatory Reform Task Force.

PARC Policy Alert 18-125, Repeal of DFARS Clause "Indefinite Quantities--No Fixed Charg-es" (DFARS Case 2018-D034), was issued on 30 Sep 18 and became effective 28 Sep 18 when DoD issued a final rule amending the DFARS to remove a clause that is no longer necessary. The removed clause is DFARS clause 252.247–7005, Indefinite Quantities—No Fixed Charges, and the associated clause prescription at DFARS 247.270–4(e). This deletion is in support of the recommendations of the DoD Regulatory Reform Task Force.

PARC Policy Alert 18-126, Repeal of DFARS Clause "Indefinite Quantities--Fixed Charges" (DFARS Case 2018-D039), was issued on 30 Sep 18 but was effective 28 Sep 18 when DoD issued a final rule amend-ing the DFARS to remove a clause that is no longer necessary. The removed clauses is DFARS clause 252.247–7004, Indefinite Quantities—Fixed Charges, and the associated clause prescription at DFARS 247.270–4(d). This deletion is in support of the recommendations of the DoD Regulatory Reform Task Force.

PARC Policy Alert 18-127, Repeal of DFARS Clause "Award Fee" (DFARS Case 2018-D037), was is-sued on 30 Sep 18 but was effective 28 Sep 18 when DoD issued a final rule amending the DFARS to remove a clause that is no longer necessary. The removed clause is DFARS clause 252.216–7005, Award Fee, and the associated clause prescription at DFARS 216.406(e)(2). This deletion is in support of the recommenda-tions of the DoD Regulatory Reform Task Force.

PARC Policy Alert 19-01, 4Q FY18 PARC Policy Alert Overview, was issued on 1 Oct 18 to provide an overview of important PARC Policy Alerts issued during the 4th Quarter of FY18.

PARC Policy Alert 19-02, Government-wide Commercial Purchase Card Guidance Related to Class Deviation 2018-O0018, was issued on 2 Oct 18 to rescind a previous GPC memorandum and provide GPC implementing guidance related to the $10,000 micro-purchase threshold (MPT) authorized for use Department of Defense (DoD) Class Deviation 2018-O0018 dated 31 Aug 18. Government Purchase Cardholder's single purchase limit may be raised up to $10,000 if funding is available and a determination is made that anticipated mission requirements and historical spending patterns demonstrate a need for raising the single purchase limit.

A new GPC Delegation of Procurement Authority Letter must be issued. Cardholders with a single credit lim-it above $3,500 up to $10,000 - the requirement to set-aside purchases for small businesses and the need to obtain 3 quotes does not apply. Note: The single purchase limit for services remains at $2,500, construction at $2,000, and convenience checks at $5,000.

https://www.gpo.gov/fdsys/pkg/FR-2018-09-26/pdf/2018-20709.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20971.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20972.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20972.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20974.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20974.pdf https://www.gpo.gov/fdsys/pkg/FR-2018-09-28/pdf/2018-20973.pdf https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-01%204Q%20FY18%20PARC%20Policy%20Alert%20Overview%20GFoley.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-02%20Government-wide%20Commercial%20Purchase%20Card%20Guidance%20Related%20to%20CD%202018-O0018%20MMcIllwain.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-02%20Government-wide%20Commercial%20Purchase%20Card%20Guidance%20Related%20to%20CD%202018-O0018%20MMcIllwain.msg

P A G E 8

PARC Policy Alerts (Continued)

PARC Policy Alert 19-03, Intelligence Training Requirements, was issued on 5 Oct 18 to inform contract-ing officers of certain requirements related to contracts in DoD Directive 5148.13, Intelligence Oversight dat-ed April 26, 2017. Contracting officers for contracts involving the conduct of intelligence or intelligence relat-ed activities should be aware of this information in the event that the requiring activity requests clarification on the appropriate performance requirements to be included in contracts.

PARC Policy Alert 19-04, FMS - Interim Clarification on 10 USC Section 333, DSCA Policy 18-38, was issued on 5 Oct 18 to announce a memo issued by Defense Security Cooperation Agency (DSCA) on 5 Sep 18 providing interim guidance for programs utilizing the title 10 Section 333 authority. This memorandum clarifies the use of funds, explains the requirement for synchronized start, updates guidance for funds availa-bility and Period of Performance, addresses Travel and Allowance Carry-Over, restates the production/long lead-time exception, and establishes new case notes for Letters of Offer and Acceptance (LOAs).

PARC Policy Alert 19-05, Government-wide Commercial Purchase Card Guidance Related to GPC SmartPay 3 Transition, was issued on 9 Oct 18 to announce the DoD Jun 18award of the the Department of the Army/Department of the Air Force/Defense Agencies and Activities SmartPay3 (SP3) Tailored Task Or-der (TTO) to U.S. Bank. The terms of the subject TTO and applicable GSA SP3 Master Contract require that the transition from SP2 to SP3 include the closing of all SP2 GPC accounts, creation of new GPC accounts, and issuance of new purchase cards to all cardholders. Accordingly, new accounts and cards will be estab-lished for all purchase cardholders. Existing SP2 accounts will expire at 11:59 pm Central Standard Time (CST) on 29 November 2018. Charges made prior to that time will be processed through the regular/billing/ payment cycle of the old accounts. New SP3 accounts will commence at midnight CST on November 30, 2018. The Army must be in a position to begin operations under SP3 by 30 Nov 18. The attached provides specific guidance on how the Army plans to achieve its goals for SP2 closeout and a successful transition to

SP3.

PARC Training Alert 19-01, Required AbilityOne Program Training for DoD Contracting &Purchasing Acquisition Career Fields, was issued on 2 Oct 18. As a result of recommendations from the Department of Defense (DoD) Office of Inspector General (IG), report number DoDIG-2016-097, "DoD Gen-erally Provided Effective Oversight of AbilityOne Contracts", and from the Panel on DoD and AbilityOne Contracting Oversight, Accountability, and Integrity ("the Panel"), all Contracting and Purchasing personnel are required to take the recently updated Defense Acquisition University (DAU) online Continuous Learning Module (CLM) 023, "DAU AbilityOne Training" accessible at the DAU iCatalog website http:// icatalog.dau.mil/onlinecatalog/courses.aspx?crs_id=418.

PARC Training Alert 18-08 Rev 2, VCE PCF Customer/Contracting Training Schedule, was issued on 2 Oct 18 to provide the October schedule for the Virtual Contracting Enterprise (VCE) Paperless Contract File (PCF) training via Defense Collaboration Services (DCS). Several types of training, including training for requirements owners--identified as Customer Training--are available. Schedule is linked in the announce-ment.

PARC Information Alert 19-01, The Richard “Dick” Ginman Contingency Contracting Officer Excel-lence Award, was issued on 2 Oct 18 to Request nominees for the Richard " Dick" Ginman Contingency Contracting Officer (CCO) Excellence Award. This annual award, established in 2013, acknowledges the CCO who best exemplifies Mr. Ginman's tireless support of the Contingency Contracting Community during fiscal year 2018. The memorandum at Reference 1 provides nomination eligibility and criteria. Commands should submit nomination packages no later than COB 16 November 2018, to Ms. Dorothy Smith, 703-697- 1052, dorothy.c.smith.civ@mail.mil.

https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-03%20Intelligence%20Training%20Requirements%20RMoye.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-04%20FMS%20-%20Interim%20Clarification%20on%2010%20USC%20Section%20333%20DSCA%20Policy%2018-38%20CFluellen.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-05%20GCPC%20Guidance%20Related%20to%20GPC%20SmartPay%203%20Transition%20MMcIllwain.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Policy%20Alert%2019-05%20GCPC%20Guidance%20Related%20to%20GPC%20SmartPay%203%20Transition%20MMcIllwain.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Training%20Alert%2019-01%20Required%20AbilityOne%20Training%20for%20DoD%20Contracting%20Purchasing%20CF%20SUS%2030%20SEP%2019%20EGDawsonJr.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Training%20Alert%2019-01%20Required%20AbilityOne%20Training%20for%20DoD%20Contracting%20Purchasing%20CF%20SUS%2030%20SEP%2019%20EGDawsonJr.msg http://icatalog.dau.mil/onlinecatalog/courses.aspx?crs_id=418 http://icatalog.dau.mil/onlinecatalog/courses.aspx?crs_id=418 https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Training%20Alert%2018-08%20Rev%202%20VCE%20PCF%20CustomerContracting%20Training%20Schedule%20SUS%20Multiple%20ARothschild.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Information%20Alert%2019-01%20The%20Richard%20Dick%20Ginman%20CCO%20Excellence%20Award%20SUS%2016%20Nov%2018%20DSmith.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Information%20Alert%2019-01%20The%20Richard%20Dick%20Ginman%20CCO%20Excellence%20Award%20SUS%2016%20Nov%2018%20DSmith.msg

P A G E 9

PARC Policy Alerts (Continued)

PARC Information Alert 19-02, Acquisition Exchange Program, was issued on 5 Oct 18 to announce the next cycle of career-broadening Acquisition Exchange Program (AEP) opportunities for government employ-ees. Interested individuals are required to submit applications to Mr. Adam Gertz (adam.l.gertz.ctr@mail.mil) no-later-than 16 November 2018.

PARC Information Alert 19-03, IDEAL Leadership Program, was issued on 5 Oct 18. The Inspiring and Developing Excellence in Acquisition Leaders (IDEAL) opened for applications 1 Oct 18 and closes 4 Jan 19.

IDEAL is a leader development program for mid-career acquisition professionals (GS-11-13/equivalent). For FY19, there will be two offerings of the IDEAL program - one in Warren, Michigan (for those in the commut-ing distance of Warren only) and one in Washington, DC (the National Capital Region). Applicants will sub-mit their packages in the Army Acquisition Professional Development System (AAPDS).

ACC Contracting Note 18-31, Emergency Declaration, Hurricane Florence Micro-Purchase Threshold Increases, was issued on 12 Sep 18 to re-emphasize the importance of PARC Policy Alert 18-115 to apply the Micro-Purchase threshold increases to DoD acquisitions of supplies or services funded by DoD appropria-tions that are to be used to support Hurricane Florence relief operations.

From the September 2018 Bulletin Contracting Question of the Month the correct answer is a see FAR

32.702.

The Anti-Deficiency Act states no officer or employee of the Government may:

a. Create or authorize an obligation in excess of the funds available, or in advance of appropriations (Anti-

Deficiency Act, 31 U.S.C. 1341), unless otherwise authorized by law

b. Authorize a contractor to commence work without a signed contract

c. Incrementally fund a contract

d. Allow a contract to cover more than one fiscal year

Authority for entering into or modifying contracts in order to facilitate the na-tional defense under extraordinary emergency conditions is granted by:

a. The head of the contracting agency

b. A level above the contracting officer

c. The Secretary of Defense

d. Public Law 85-804 https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Information%20Alert%2019-02%20Acquisition%20Exchange%20Program%20SUS%2016%20Nov%2018%20RFoston.msg https://spcs3.kc.army.mil/asaalt/zp/doccenter/Documents/PARC%20Information%20Alert%2019-03%20IDEAL%20Leadership%20Program%20SUS%204%20January%202019%20DSmith.msg https://acc.aep.army.mil/Contract_Operations/Contract_Policy/SharedDocs/Forms/AllItems.aspx?RootFolder=%2FContract%5FOperations%2FContract%5FPolicy%2FSharedDocs%2FContracting%20Notes https://acc.aep.army.mil/Contract_Operations/Contract_Policy/SharedDocs/Forms/AllItems.aspx?RootFolder=%2FContract%5FOperations%2FContract%5FPolicy%2FSharedDocs%2FContracting%20Notes