Guidance clarifies mandatory sources for contracted services

By April 15, 2013June 8th, 2014Contracting
MICC small business specialists
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By Daniel Elkins


JOINT BASE SAN ANTONIO-FORT SAM HOUSTON, Texas (April 12, 2013) — Acquisition workforce members in the Mission and Installation Contracting Command (MICC) are following revised procedures aimed at ensuring equitable consideration between small businesses and nonprofit agencies for award of Army contracts.

The MICC command policy memorandum on the required sources for the acquisition of service published March 18 provides explicit guidance on contracting sources to ensure appropriate acquisition strategy decision-making by MICC contracting officers, according to Lynette Ward, an assistant director for MICC Small Business Programs here.

The guidance also ensures procurement actions meet statutory requirements established by the Federal Acquisition Regulation (FAR). Part 8 of the FAR identifies required sources of supplies and services while Part 19 implements the use of small business programs.

“It clarifies mandatory source procedures, stresses the importance of adequate market research, and provides a standardized decision-making process when developing acquisition strategies,” she said. “This will enable contracting officers to appropriately satisfy their zest for supporting both the AbilityOne program and maximizing opportunities for small business.”

The policy requires members of the contracting workforce to accomplish necessary planning and market research to provide for the acquisition of commercial items and promote full and open competition to ensure that customer requirements are being met in the most efficient, effective, economical and timely manner. Procurement planning includes a determination of what sources exist to meet the government’s needs. The number and nature of the sources factor into that procurement strategy.

The Javits-Wagner-O’Day Act requires the government to purchase available supplies or services on a procurement list from participating nonprofit agencies at prices established by the U.S. AbilityOne Commission. Those services may include janitorial and custodial, administrative, document management, call centers, fleet management, warehousing and distribution of federal supplies, full facility management, recycling, food service, laundry, and grounds maintenance.

The commission sets and approves a fair market price for products and services on the procurement list when purchased from designated nonprofit agencies. For a commodity or service to be added to the procurement list, a set of criteria must be satisfied in accordance with federal codes.

The FAR allows contracting officers to acquire services not on the procurement list from other sources. AbilityOne nonprofit agencies may continue to compete for such contracts without preference or priority unless a potential agency has its own status under a socioeconomic program.

Ward said small business specialists located at MICC contracting offices throughout the nation are called upon to engage early in the acquisition process to provide guidance to contracting personnel and customers on the consideration of small business.

“Supporting both the AbilityOne Program as well as small business programs such as woman-owned and service-disabled veteran-owned small businesses assists in strengthening our nation’s economy,” Ward said.

She added the clarifying policy, available at the MICC SharePoint site, also benefits the command’s mission partners with the timely delivery of customer service.

“Having clear guidance will expedite the procurement process, allowing contracting officers to engage the most effective strategies to meet customer needs,” Ward said.

The MICC is responsible for providing contracting support for the warfighter throughout Army commands, installations and activities located throughout the continental United States and Puerto Rico. Its primary supported activities include the U.S. Army Installation Management Command, U.S. Army Forces Command, U.S. Army Training and Doctrine Command, U.S. Army North, U.S. Army Reserve Command and U.S. Army Medical Command.

In fiscal 2012, the command executed more than 58,000 contract actions worth more than $6.3 billion across the Army, including more than $2.6 billion to small businesses. The command also managed more than 1.2 million Government Purchase Card Program transactions valued at an additional $1.3 billion.