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Competitive Sourcing Team Members:
We previously published the agenda for our January 27 meeting focusing on the 2005 FAIR Act inventory. The purpose of the meeting is to develop a more consistent and accurate DOI inventory. We don't expect the OMB guidance on '05 inventory preparation until the end of February but we all know there is a lot of internal DOI clean up we can do prior to receiving that guidance. We have been told that the format of the inventory is not expected to change.
To aid us in getting as much accomplished as possible on the 27th and beyond, we have created a "straw man" of sorts for 12 of the larger functional areas common to most bureaus. In this case, each "straw man" consists of information on where FTE are currently coded, numbers of FTE and in many cases, suggestions on consolidation of coding and consistent application of OMB function codes. As you know, a "straw man" (or straw person) can easily be knocked down so we don't want you to think any of these recommendations are final or so etched in our thinking that they can't be changed. The meeting is about making constructive changes to the inventory.
Therefore, we ask you to take some time prior to the meeting to review this information. Come on the 27th ready to work together with other bureaus to come up with more consistent, accurate inventory coding.
We also need to revisit the definitions of "inherently governmental" and "Commercial A - not appropriate for competition (core to the mission)". In the past, several program offices (acquisition, finance, fire and others) have issued memorandums to all bureaus defining which FTE in their program areas were considered inherently governmental. Some of these memorandums may need to be updated. We get lots of calls asking for a clearer definition of "inherently governmental". Besides referring you to the language in the A-76 Circular or the Federal Acquisition Regulations, consider the following:
- An inherently governmental function must be peformed by a government employee. Therefore, if you have contractors performing a function, that function isn't inherently governmental. It may be that the government FTE assigned to that function are "core to the mission of the bureau" in which case you would write a justification to code the FTE as "Commercial - Reason Code A - not appropriate for competition". Reason Code A justifications should be submitted to our office with the '05 inventory. We are required to review and submit them to OMB for review.
- Another example of an inherently governmental function would be an FTE (actually a real person) who issues policies - not the FTE who do research and write policy - the FTE responsible for issuance and who is responsible for carrying out that policy.
- Even if you don't currently have contractors peforming a certain function, if it is readily available in the private sector, it is likely not inherently governmental.
- We will have a chance on the 27th to discuss this issue further - just wanted to give you some food for thought.
thanks - we look forward to a productive meeting on the 27th.
Function Code Definitions:
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