The proposed policy would require each agency with 100 or more full-time federal employees to identify one or more senior officials to be accountable for the development and implementation of agency policies, procedures, and training to ensure certain functions are appropriately reserved for federal employees.
The selected officials would be expected to get all relevant offices meaningfully involved in the effort, and agencies would be expected to maintain internal procedures and develop training to help employees understand and meet their responsibilities.
Prior to new contract solicitations, an agency head or designated “requirements official” would be required to document how the work in question is not inherently governmental.
The letter includes examples of inherently governmental functions such as the direct control of federal employees, determination of agency policy, and contract administration. Examples of closely associated work, such as technical evaluation of contract proposals, are also spelled out.
Agencies would be required to monitor contract performance – especially where it’s closely associated with inherently governmental work, and take action where internal control of mission and operations is at risk due to inappropriate or excessive reliance on contractors to perform critical functions.
