Justice Management Division...Serving Justice - Securing Results

1. What are these new policies from the Office of Federal Procurement Policy (OFPP)?

The first is OFPP Policy Letter 05-01 found at http://www.fai.gov/pdfs/policy0501.pdf.  This policy letter establishes new training requirements for the entire civilian acquisition workforce and new certifications in targeted acquisition career fields. It mandates the workforce’s use of a federally based training database, ACMIS. The policy letter also establishes a new position, Acquisition Career Manager (ACM), at each agency, to monitor and manage the training and certification of the acquisition workforce within their agency. The Office of Federal Procurement Policy Letter 05-01 applies to all of the federal executive agencies.

The second is Office of Management and Budget (OMB) memo, dated 06-01 found at http://www.whitehouse.gov/omb/procurement/acq_wk/fac_contracting_program.pdf. This memo establishes the requirements and guidance for the Federal Acquisition Certification in Contracting (FAC-C), which is a federally recognized program for the acquisition workforce that sets forth the required training, experience and education for certification of contracting professionals.  The OMB Memo applies to all federal executive agencies except those that are subject to Defense Acquisition Workforce Improvement Act (DAWIA).

2. What are the requirements for obtaining FAC-C?

Achievement of the FAC-C is based on three cumulative requirements: education, training, and experience, as shown in Figure 1. There are three levels and the employee must meet the requirements of each previous certification level before progressing. All Contracting Officers (COs) issued an unlimited warrant on or after January 1, 2007 must initially qualify for and maintain a Level III certification by completing the 80 Continuous Learning Points (CLPs) every two years. The chart is available on FAI.gov at http://www.fai.gov/certification/specialist.asp.

3. Who will the new FAC-C program affect?

The FAC-C program will affect individuals employed in the Federal Acquisition workforce. PL 05-01 defines the FederalAcquisition Workforce as 1102s and Civilian uniformed personnel in comparable positions, all Contracting Officers (COs) regardless of Series with authority to obligate funds above the micro-purchase threshold, 1105s, Program/Project Managers, Contracting Officer Representatives (CORs), Contracting Officer Technical Representatives (COTRs) and any other positions identified by the U.S. Department of Justice (DOJ) Chief Acquisition Officer (CAO).The FAC-C program applies to all executive agencies, except those subject to DAWIA.

4. Is it required that I obtain FAC-C?

The federal certification in contracting is available to all members of the federal acquisition workforce but is not mandatory. However, members of the workforce issued new Contracting Officer (CO) warrants after January 1, 2007, regardless of GS series, must be certified at an appropriate level to support their warrant obligations, pursuant to Departmental policy.
The FAC-C requirement does not apply to:

• Senior level officials responsible for delegating procurement authority;
• Non-1102s whose warrants are generally used to procure emergency goods and services;
• Non 1102s whose warrants are so limited as to be outside the scope of this program.

In addition to the FAC-C exemptions from OFPP, the DOJ CAO has exempted the following warrants from the requirements of the FAC-C program:

• Non-1102 field division employees with limited warrants $25K or less;
• Non-1102 employees in the Offices, Boards, and Divisions requiring warrants as a co-lateral duty;

NOTE: On or after January 1, 2007, if you transfer to another civilian agency as a CO requiring a warrant, FAC-C will be required at an appropriate level to support the warrant delegation. FAC-C certificates are transferable to all civilian agencies.

5. How do I know if I’m subject to the new FAC-C?

Generally, anyone receiving a warrant at their agency or department for the first time after January 01, 2007 must have a FAC-C. CORs are not required by OFPP to hold FAC-C.

6. How will the new FAC-C affect my current warrant?

Current warrant holders, whom have satisfied existing training, education, and experience requirements mandated by OPM Qualification Standards, are eligible for FAC-C certification at the corresponding certification level.  

7. Are there any exceptions to the requirements granted?

There are no exceptions to the requirements and candidates must provide evidence of this to their ACM. In accordance with the Qualification Standard, employees in GS-1102 positions will be considered to have met the standard, including the education requirement, for positions they occupied on January 1, 2000. The qualification standard, which contains specific requirements, can be viewed on www.opm.gov.

8. What is the application process for obtaining the FAC-C?

• Complete and submit the applicable FAC-C application and all supporting documentation in accordance with Bureau procedures, which shall include supervisory, component ACM, and BPC approval;
• After receiving BPC concurrence, the request for issuance of FAC-C recognition, FAC-C application and copies of all supporting documentation shall be forwarded to the DOJ ACM;
• After reviewing and concurring on the information submitted, the DOJ ACM issues the official FAC-C certificate. Before the FAC-C is issued, ACMIS must reflect employees’ true, current, and accurate information.

9.  Are there any requirements for maintaining FAC-C?

Maintenance of FAC-C is a function of continuous learning.  Effective January 1, 2007, GS1102s, 1105s, and other COs warranted above the micro-purchase threshold are required to earn 80 CLPs of skills currency training every two years to maintain their federal acquisition certification. CORs are encouraged to earn 40 continuous learning points of skills currency training every two years. The OFPP Administrator may prescribe specific CLPs to ensure that training is provided to the acquisition workforce on topics such as ethics, performance-based contracting, strategic sourcing, or others, as needed.

10. What happens if I obtain FAC-C and don’t maintain 80 CLPs every two years?

Your FAC-C will expire and you may have your warrant suspended or revoked until the skills currency requirement is met. CORs may have their appointment suspended or rescinded until their skills currency requirement is met. Limited waivers are available.

11. What is the two-year time frame for the CLP requirement?

OFPP states that the first period will begin on 10/1/07 and end on 9/30/09. Agencies may choose to implement the CLPs sooner or give credit for previous training. Department policy allows Components to grant credit towards the 80 CLP requirements for training completed after January 1, 2007.

12. Who keeps track of my CLPs?

Each employee is responsible for regularly updating their training activities in the ACMIS system. The supervisor is responsible for verifying compliance with the training requirements and for validating the information entered into ACMIS.  A record of all activities completed to satisfy CLP requirements should be maintained with supporting documentation. All activities must be job-related.

13. I want to be certified but I took my classes in the 1970s or 1980s. Will I have to retake the acquisition courses?

There is a fulfillment process for the acquisition workforce who may be considered “legacy” (took most of the training before 1994). Through the fulfillment process, you will be asked to demonstrate that you possess the core competencies of the new courses.

14. What do you mean by fulfillment and how does it work?

Fulfillment is equivalent to completing the actual certification course.  Contracting professionals are required to possess all the competencies of a required class in order to fulfill that class. Individuals may use work experience, education, or other training to demonstrate the competencies associated with a required certification course.

15. I am already DoD certified (DAIWA). Do I have to do anything more?

The employee must have proof of DAIWA certification. When applying for FAC-C certification, a copy of the DAIWA certification must be included with the application.

16. Is the DAIWA certification equivalent to a FAC-C?

A valid, current DAWIA certification in contracting is equivalent to a FAC-C at the same certification level. The employee is responsible for providing the necessary documentation of the DAWIA certification and the appropriate continuous learning history to ensure validity and currency of DAWIA certification.

17. Will the DOJ Senior Procurement Executive (SPE) grant waivers to the FAC-C?

The SPE may waive the requirement for obtaining a certification for warranting purposes in writing, on a case-by-case basis, if granting the waiver is in the best interest of the Department. Waivers issued by the Department are time-driven with an expiration date, usually two years from the date of issue and are based on the employee agreeing to meet criteria before the waiver’s expiration. The education waivers are not transferable to another agency and do not satisfy the education requirement for a FAC-C.

18. I have already completed the previously required acquisition courses. How am I affected?

All new or recently hired acquisition professionals to the Department must follow the DAU curriculum (if applicable). Existing employees should transition into the DAU curriculum as soon as practicable. For example, if an associate has finished the first six (6) legacy courses (beginning with Acquisition/Procurement Planning I), they may transition to the DAU curriculum by taking CON 202, in lieu of the next three (3) legacy courses.

Employees choosing to complete the legacy courses should do so as soon as possible as it is not certain how long training providers will continue to offer the curriculum. An employee who will not be able to complete the legacy training courses by the specified cut-off dates must follow the DAU curriculum. The employee’s supervisor makes the final decision concerning what curriculum the employee should follow.

19. What if I completed courses that were not DAU or DAU equivalent courses?

If an employee completed courses that were not DAU/DAU equivalent courses, he or she must provide for each competency the dates of training, course descriptions, provider names, grades (if applicable), and competencies achieved, to the maximum extent practicable.The Interagency Acquisition Career Management Committee (IACMC) and FAI will review course information to determine if the necessary competencies were presented to fulfill all or part of a course requirement, and make this information available on www.fai.gov.

20. Who can I contact if I have concerns about the FAC-C?

The DOJ Acquisition Career Manager (ACM), co-laterally with Component ACMs, is responsible for managing the certification process, including verification and assessment of applications. Authority for overseeing the agency FAC-C program, resolving disputes, and granting certifications shall be at the Senior Procurement Executive (SPE) level. The SPE may delegate, in writing, certain functions down to the ACM as needed. However, the SPE may not delegate the waiver function. Each DOJ component shall internally manage their FAC-C program and shall make every effort to resolve issues and disputes internally.

21. What are the training requirements for CORs/COTRs?

The Department requires attendance and successful completion of at least 16 hours of COTR training and 1 hour of procurement ethics training before appointment. OFPP encourages CORS/COTRS to complete 40 hours of CLPs every two years. FAI recommends a combination of the following training modules for first time CORs/COTRs:

• COR with a mission focus (CLC 106 - 8 hours)
• Contracting for the rest of us (CLC 011 - 2 hours) OR Contracting Overview (CLM 024 - 8 hours)
• Potentially: Market Research (CLC 004 - 3 hours)

22. What is ACMIS?

The Acquisition Career Management Information System (ACMIS) is a government-wide system, developed and managed by the Federal Acquisition Institute (FAI), to assist agencies in making informed budgeting, staffing, training, and employment development decisions. It also supports agencies’ requirements to maintain training records of their acquisition workforce, as directed under the Clinger-Cohen Act. All employees designated as members of the acquisition workforce must use ACMIS to track their continuous learning skills currency training every two years.

23. I am a contract specialist without a warrant.  Am I required to use ACMIS?

Yes. All employees designated as members of the acquisition workforce must use ACMIS to track their continuous learning skills currency training every two years.

24. I am an alternate COR and I rarely work with contracts.  Am I required to use ACMIS?

Yes.  In order to keep your COR status current, you must be registered in ACMIS. 

25. What personal information is required for ACMIS?

1102s and 1105s will have education, federal employment history, job series and grade, entered into ACMIS through the Office of Personnel Management’s database. Employees must update their information and training as needed.

26. Who is responsible for information in ACMIS?

ACMIS will be pre-populated by the OPM Enterprise Human Resources Integration (EHRI) for 1102 and 1105 employees.  All other members of the acquisition workforce are responsible for populating ACMIS with complete and current information. Component ACMs are responsible for ensuring that specific employee information is entered in ACMIS.  Component supervisors are responsible for reviewing and approving their employee’s information in ACMIS.  Components that maintain existing learning management systems may populate ACMIS with that information. Components needing to interface should coordinate all efforts with FAI through the DOJ ACM.  FAI has agreed to supplement costs involved in the interface process.

Bureau ACMs shall establish hard-copy files and maintain the individual employee backup information for all Bureau employees. 

27. Who has access to my personal information?

Your agency ACMIS System Administrator(s), Program Administrator(s), and your immediate supervisor may access portions of your record. Visible information includes core training courses, CLPs, job series, grade, warrant information, and education.

28. What are the time-frames for entering employee information into ACMIS?

The deadline for all members of the acquisition workforce data entry has been extended to July 1, 2007. The acquisition workforce includes all:

• Positions in the GS1102 series and non-DOD uniformed personnel in comparable positions;
• COs regardless of GS series with authority to obligate funds above the micro-purchase threshold unless exempted by OCAO;
• Positions in the GS1105 series; an
• Program/Project Managers including CORs and COTRs