UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON. D.C. 20460
                                     NOV 15
  MEMORANDUM

  SUBJECT:  Headquarters Support Contract
                                                              OFFICE OF
                                                    SOLID WASTE AND EMERGENCY RESPONSE


                                                 OERR Directive  9242.6-05
  IKW:
 TO:
       Henry L. Longest II, Director y-
       Of f ice of Emergency and Remedial

       OERR Division Directors
       Branch Chiefs
       Section Chiefs
     The Superfund program has come under increasing scrutiny in recent months,
 as evidenced by the 90-Day Study and recent Congressional Hearings.   We have
 developed the attached document outlining some of the major aspects  of current
 policies and procedures concerning the Headquarters management support
 contracts.


     This document addresses two areas:   1)  perceptions that may weaken public
 confidence in the Superfund program and its use of these  contracts,  and 2)
 procedures designed to strengthen controls  and effectiveness in the  management
 of the contracts.   It  is not all inclusive  but provides information  to be
 applied to OERR work assignments.


     I urge all of you to become familiar with this document and to ensure that
 all OERR Work Assignment Managers are given a  copy.


Attachment
oc:
OIW Project Officers
OERR Work Assignment Managers
                                                                     Pruned on RttyctufPaptr

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                              Contract Management
Introduction

    Over the course of the past year, management support contracts that assist
policy analysis and program management functions in Superfund have cone under
increasing public and Congressional criticism and scrutiny.   Among the areas of
particular concern to external critics have been the following issues:

    o   Are contractors being used appropriately to support management
        functions of the Superfund program?  Are contractors  performing
        inherently governmental functions (defined primarily  as making
        program and policy decisions)?

    o   Does Superfund management of these support contractors ensure
        efficient use of government resources?

    o   Are support contractors who are also response action  contractors
        (RACs) inappropriately influencing policy decisions that nay affect
        the manner in which they do business, thereby increasing their
        profits?

    Management of these support contractors to ensure efficient use of
resources has been of concern to OERR for some time.  We also recognize that
while several of the issues raised by outside critics may be  issues more of
perception than reality, these perceptions may undercut public confidence in
the Superfund program and therefore must be addressed.

    The following document summarizes a variety of contract management
initiatives that have been undertaken to improve management of the headquarters
support contracts, and to ensure that both real and perceived issues of
contracts management are addressed.  Most of the procedures outlined below have
been in place since the beginning of FY 1989, and are summarized below for easy
reference.  Additional procedures are under development to implement the "90-
Day Study" recommendations regarding conflict of interest. These will be added
when that work is completed.
Overview

    During the course of FY 1986-87, a special assistant to the Director of the
Office of Emergency and Remedial Response (OERR}  undertook an analysis of
contracts management practices in the office, particularly as they related to
management support contracts.  A variety of work assignments and contractor
products were analyzed and interviews were conducted to answer questions
concerning who is running the program.. .us or the contractors..., and whether
existing management practices need improvement.  While no serious problems were
identified, it was concluded that a variety of additional initiatives would be
necessary to improve management of the contracts.  These initiatives include:

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    o   Development and implementation of a mandatory course to train work
        assignment managers on the management of contractors, with a
        special emphasis on roles and responsibilities;                :

    o   Development of a contracts operating plan for each Division that
        requires Division Director sign off concerning whether certain
        activities are suitable for contracting; and

    o   Initiation of trimester performanoe reviews, followed by formal
        meetings between EPA management and contractor management, to
        review and resolve problems.

    This document is a quick reference guide for OERR employees who are
planning to use or who are responsible for work assignments under the Supex
headquarters management support contracts.  It is designed to acquaint the
reader with key contract management practices in OERR.  An appendix to this
document contains a brief description of the five major management support
contracts under the Superfund program, as well as forms associated with various
aspects of contracting procedures.

    This document does not address the whole range of contract management
procedures, but rather the special OERR initiatives designed to facilitate a
stronger contracts management program.  The OERR Work Assignment Manager
Guidebook addresses a variety of key points in work assignment planning,
preparation, management, oversight and evaluation.
                                                                           fund
Key Plavers in the Contract Management Process in OERR

    The principle people involved in the management of a contract work
assignment are the:

    Work Assignment Manager - has overall responsibility for the project.

    Branch Chief - approves establishment of work assignments and any
    subsequent amendments.

    Division Director - approves the Contract Operating Plan,  the designation
    of the Work Assignment Manager, and, for the OHMSETT contract, work
    assignments and related actions.

    Division Financial Coordinator - maintains division budget controls and
    signs work assignments indicating that funds are available.

    Project Officer - has overall responsibility for management of the
    contract, approving all work assignments,  amendments,  and payments,  and
    deals with issues affecting the contract as a whole.

    Contracting Officer - the person in the Procurement and Contracts
    Management Division whose authorization is required for all actions.

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Contract Operating Plan

    A fundamental aspect of the OERR contract management system is the Contract
Operating Plan, which is incorporated into the OERR Operating Plan.  The
Contract Operating Plan is used to identify areas suitable for contracting,
to ensure that senior management (Division Directors and Office Directors)
agree, to balance utilization of contract hours and dollars across contracts,
and to balance projected budgetary needs across divisions.

    According to the Contract Operating Plan, each division and branch begins
the fiscal year with a specific budget for each contract.  During the
branch/division planning process, and more precisely when the overall OERR and
division budgets are determined, the specific areas that will need contract
support are identified by workplan item and/or by task.  Accordingly, the
division Contract Operating Plan is broken up by branch, by task within the
branch, and by desired contract mechanism.  The Program Development and
Budgeting Staff (FOBS) in ORS will review preliminary plans and work with the
divisions to ensure an equitable allocation across divisions and across
contracts.

    Divisions will be given final budget targets and will submit revised final
contract operating plans to 0PM.  The plans will be the basis of funding work
assignments throughout the year.  If a work assignment is submitted that is  not
on the contract operating plan, the work assignment must be initialed by the
Division Director, and modifications to the operating plan submitted with the
new work assignment.

    For the management, technical and analytical support contracts, the actual
procurement requests for incremental funding of the contracts are provided to
POMD by the Project Officers of the contracts, but the funding for each work
assignment is deducted from the amount allocated to each branch and division in
the budget for the contract.  Within the limits of the division budget ceiling,
each division has authority to transfer funding from one cunt-tact to another,
or through the amendment process, fr*"**1 one work assignment to another.

    Any non-OERR work assignments are funded by separate procurement requests
from the offices responsible for the work assignment.  Ihe OHMSEIT contract  is
entirely funded by specific procurement requests for the work assignments.

    Contract operating plans are prepared within the limits of the contracts
with Division Director approval.  Concepts for work are turned into work
assignments by the division staff.
Writing Statements of Work

    It is advisable for a Work Assignment Manager to discuss a proposed work
assignment with the Project Officer to determine the appropriateness of the
project to the contract Statement of Work and for guidance on the information
and approvals required.  Only work specifically provided for in the contract
may be assigned to the contractor.  Any work that could be identified as
"personal services" is forbidden.

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    A typical statement of work includes;

        Background information and purpose of the work assignment;

        An outline of the actual tasks involved in the project;

    *  A schedule of deliverables;

        The estimated number of hours the project will require;

        The period of performance anticipated for the project; and

    -  An estimate of funds to be dedicated to this work assignment from the
        division budget.

    NOTE:  The budget estimate is not included in the document sent to the
    contractor but must be planned.  Ihe signature of the Division Director and
    the Division Financial Coordinator indicate that estimated funds are
    available.  Reminder:  All work assignments should be part of the division
    operating plan.

    Sloppily written work assignments often lead to misperceptions of the
relationship of contractors and EPA staff in conducting their roles and
responsibilities.   There are certain inherently governmental functions that
contractor staff is not allowed to perform (see attached definition of
inherently governmental functions) .  Key among these is the decision-making or
policy-making function.  Although internal analysis suggests that there are few
issues in the actual operations of work assignments, broadly written work
assignments often fail to adequately distinguish between the government's role
and the contractor's role.

    Statements of Work should be clearly drafted to explain to the contractor,
to EPA staff, and to any external reviewers of EPA's use of contracts, what the
contractor is expected to do, and the role and timing of EPA in reviewing that
work and in making decisions.  Some examples of key phrases to use in writing
a Statement of Work include:  compile policy decisions by the Agency into draft
documents (or regulations) , assist the agency in identifying options, under
the direction of, research and analyze data for the purpose of facilitating
agency evaluation.  Types of phrases that should not be used are:
options or policy, write guidance or regulations, develop a strategic
approach, evaluate, etc..


Training Requiren^ents for Work Assignment Managers

    The Procurement and Contracts Management Division requires that all
personnel designated as Work Assignment Managers have the requisite training
before undertaking the responsibility.  If the required POMD Contract
Administration course is not available, a temporary waiver is necessary until
the training can be completed.  The prospective Work Assignment Manager
indicates training and contract experience on the Designation of Work
Assignment Manager form, which is signed by the Division Director and sent
through the Project Officer to the Contracting Officer.  Requirements for Work

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Assignment Managers are provided in the PCMD contract Management Manual and
are discussed in depth in the Work Assignment Manager training course and
associated guides >

    As part of OERR's contract management program, OERR has developed a
specialized training course aimed at the needs of Work Assignment Managers.
Ihis course addresses management of contractor resources and a variety of
project management roles and responsibilities such as developing work
assignments, monitoring work, ethical responsibilities, giving feedback to
contractors, evaluating work, etc.  Completion of this course is mandatory for
all OERR Work Assignment Managers.

    The Work Assignment Manager course has been given to all current OERR Work
Assignment Managers.  As new employees enter OERR, they will be scheduled for
attendance at a course.  No OERR enployee can be a Work Assignment Manager for
more than six months without this course unless a waiver has been granted by
the Office Director.  Application for a waiver should be submitted to the
Director of the Office of Program Management.


Work Assignment Evaluation

    Project management is an on-going part of the Work Assignment Manager's
responsibilities.  OERR has implemented a formal evaluation of all work
assignments every trimester.  The purpose of this evaluation is to identify
specific problems with contractor performance, and any systemic problems that
should be brought to management attention.

    Appendix II includes the basic evaluation form.  Work Assignment Managers
are encouraged to include remarks necessary to fully explain problems (or
successes) encountered in working with the specific contractor. The paragraphs
below describe the specific process used for these contracts.

    For the Headquarters management support, technical support and analytical
support contracts, a schedule is set up at the beginning of the fiscal year for
the trimester evaluations.  Before each due date, evaluation forms are sent to
the Work Assignment Managers by the Project Officer.  Responses are analyzed
and a summary is provided to the contractor.  The evaluation concludes with a
meeting of OERR and contractor management to dj»?*gg progress and  any issues.
Problems will have been dealt with long before this evaluation meeting through
the efforts of the Work Assignment Manager, the Project Officer and contractor
staff, but the management review provides for an effective overview of
progress.  Strong points are noted and ideas are developed for strengthening
weaker areas.
        OHMSETT management support contract is evaluated semi-annually.   Work
Assignment Managers evaluate their work assignments and designated officials
review all evaluations to determine award fees.  Ihe evaluation team consists
of the following: Fee Determination Official, Performance Evaluation Board,
Evaluation Coordinator, PER Executive Secretary, and Performance Monitors.

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Conclusion

    In conclusion, it is worthwhile to re-emphasize the importance of the role
of the Work Assignment Manager.  The Work Assignment Manager has major
responsibility for the work assignment.  Its success involves  the  coordinated
efforts of the program officer, the Work Assignment Manager, the Project
Officer, and the contractor, but the Work Assignment Manager is in the  lead.


Appendix I   Summary of the five Management Support contracts

Appendix II  Copies of the Evaluation Forms, Cover Sheets

Appendix III Definition of "Inherently Governmental Function"

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                                                                  Appendix I
                   Headquarters Management Support Contracts


Booz. Allen & Hamilton. Inc. £68-01-73761

    She Booz, Allen & Hamilton contract is designed to provide management
and technical services to support EPA in the areas of planning, management,
implementation, and evaluation of the Superfund program.   It is a oost-
reimbursable-f ixed-f ee contract managed by OEM and provides contractor support
to the various Divisions of OERR.  Procurement requests for incremental funding
of the contract are submitted to PCMD periodically to cover work assignments.

    Seme of the specific areas of activity are:  compilation and analysis of
data, assistance in the preparation of briefings and abstracts to support
presentations made by EPA staff, assessments and surveys of workforce and
training needs, information management support, and evaluation of existing
policies and procedures in terms of function and effectiveness.

    Contractor performance evaluations are conducted on a trimester basis.

Contract Expiration Date:  8/31/90


ICF. Inc. f68-01-7389)

    3he ICF contract is designed to provide support in planning,  managing,
implementing and evaluating Superfund's policies and program in some of the
following areas:  amendments to CERCIA; legislative analysis; RCRA/CERdA and
other cross-program issues; NCP and other CERCIA and Clean Water Act regulation
developments; response policy issues; CERCIA camiunity relations program; State
programmatic issues; interagency coordination and policy support; economic
impacts; and technological and health effects issues.  It is a cost-
reijiibursable-fixed-fee contract.  Procurement requests for incremental funding
of the contract are submitted to PCMD periodically for work assignments.

    ICF will conduct research, prepare reports, analyze issues, prepare
briefing materials, develop training and workshop materials and conduct the
training/workshop sessions, and assist in the analysis and response to comments
on notices in the Federal Register.

    Contractor performance evaluations are conducted on a trimester basis.

Contract Expiration Date:  4/14/91

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                                      -2-
CH2M Hill  (68-W8-0098)

    Hie CH2M Hill contract is designed to provide technical support and
recommendations to EPA.  Some of the areas of activity are:  development of
integrated methodologies for the selection of technical options; technical
assistance to OSWER offices and EPA Regions; assistance in coordinating with
other EPA offices and federal and State agencies; general technical develop-
ment and case studies; issue papers, technical assessments and analysis
       ing EPA's ground water strategy; ROW/CTJOA interface; site
identification; interagency agreements; remedy selection criteria;  and design
and construction support.  It is a cost-reimbursable-fixed-fee contract.
Procurement requests for incremental funding of the contract are submitted
periodically to PCMD to cover work assignments.

    Contractor performance evaluations are conducted on a trimester basis. .

Contract Expiration Date:  6/30/91


OHM5ETT f68-03-3450)                                                  '

    The OHMSETT contract offers a range of technical and managerial services to
the program offices within EPA which address hazardous and solid waste and the
release of oil and hazardous materials to the environment.  OHMSETT encompasses
the following four broad areas of technical activity:  testing and evaluation
of new technologies for remedial actions at hazardous waste sites,  studies and
evaluation under the Air Toxic Release Program, program management assistance
for the OSWER hazardous and solid waste programs, and studies related to  the
release of oil and hazardous materials.

    The OHMSETT contract is a cost-plus-award-fee contract managed by the
Project Officer through Cincinnati's Procurement and Contracts Management
Division.  Funding is provided through a separate procurement request for each
work assignment.

    This contract is evaluated semi-annually.  Work Assignment Managers
evaluate their work assignments, and designated officials review all
evaluations to determine award fees.  The evaluation team consists of the
following:  Fee Determination Official, Performance Evaluation Board,
Evaluation Coordinator, PER Executive Secretary, and Performance Monitors.

Contract Expiration Date:  9/30/91
Kendrick & Company 8a Contract f68-W8-01191

    The Kendrick & Company contract provides various types of administrative
support.  The contract consists of two categories of work:   level  of effort-
cost reimbursable tasks ordered through Task Instruction Document  A (TID-A),
and fixed rate tasks ordered through Task Instruction Document B (TID-B).

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                                      -3-
    The level of effort tasks include such services as logistical arrangements
and support for conferences and meetings; graphics and art work;  preparing
materials for nailing or distribution; and data input and support to CERR
databases.  These tasks require the approval of the Contracting officer.

    The fixed rate tasks include typing, editing,  proofreading, and
photocopying.  These tasks are approved by the Project Officer.   Procurement
requests for incremental funding of the contract are submitted to PCMD
periodically, so that there is always adequate funding to cover all tasks.

Contract Expiration Date:  9/30/91

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 CONTRACT NUMBER:  68-01-7376
                              CONTRACTOR:  Booz, Allen & Hamilton,
                                          4330 East West Highway/
                                          Bethesda, MD  20814
 WORK ASSIGNMENT NO.
                                 AMENDMENT NO.
 WORK ASSIGNMENT TITLE:
 PURPOSE:
COMMENT:
./ /   New work Assignment'
fj   Work Assignment Amendment
f~7   Work Plan Approval
LEVEL OF EFrORT  (LOE) AUTHORIZED:
    Previous Hours: 	
    This Action:    	
    Total:
                          Previous Dollars:
                          This Action:
                          Total:
PERIOD OF PERFORMANCE:  Fran:
                                         To:
•Effective date of this action  is Contracting Officer's signature date unless
 otherwise specified.
(Signature)
                          (Date)
(Mail Code)      (Phone t)
Work Assignment Manager

 Division Director
Division Financial Coordinator   (funds are available from Division allocation)
                                                        OS-240         475-9747
Project Officer, Frances J. Hanavan
                             Date
                                                        PM214F
                                                         382-X-10 i
Contracting Officer,  Calvin McWhirter    Date
                              CONTRACTOR'S ACCEPTANCE
Signature:
Title:
                                                            Date:
             Vice President

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CONTRACT NUMBER:  68-01-7389    CONTRACTOR:  ICF, Inc.
                                             9300 Lee Highway
                                             Fairfax, VA 22031-1207
WORK ASSIGNMENT NO. 	   Amendment No. 	

PURPOSE:   	 Initiate New Work Assignment  	  Work Plan Approval

	 Disapprove Work Plan 	 Statement of Work Amendment 	 Work Plan

Revision (	 SOW	 LOE) 	 Extend Completion Date to 	

	 Closeout 	 other 	

Comment:
WORK ASSIGNMENT TITLE
LEVEL OF EFFORT (LOE) AUTHORIZED:
Previous Hours
This Action
Total
                                        Dollars
PERIOD OF PERFORMANCE:  From:
                                                   To:
Effective date of this action is Contracting Officer's signature date
unless otherwise specified.
                                 APPROVALS
(Signature)
(Date)
                                                 (Mail Code)
                                                                (Phone #)
Work Assignment Manager
Branch/Division Approval
(Funds are available from Division Allocation)
Project Officer, Nancy 0. Livingstone
Contracting Officer, Calvin McWhirter
                                                   OS-240
                                                   PM-214F
                                                                 475-9339
                                                                 382-3201
Signature:
Title:
                          CONTRACTOR,S
                                                 Date:

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CONTRACT NUMBER:   68-W8-0098    CONTRACTOR:  CH2M Hill
                                             628 Herndon Parkway
                                             Herndon, VA 22070
WORK ASSIGNMENT NO. 	   Amendment No. 	                      • •  - ?

PURPOSE:   	 Initiate New Work Assignment  	  Work Plan Approval

	 Disapprove Work Plan 	 Statement of Work Amendment 	Work Plan-

Revision (	 SOW	 LOE) 	 Extend Completion Date to	

	 Closeout 	 Other 	;	

Comment:
WORK ASSIGNMENT TITLE
LEVEL OF EFFORT  (LOE) AUTHORIZED:
Previous Hours
This Action
Total
    Dollars
PERIOD OF PERFORMANCE:  From:
               To:
Effective date of this action is Contracting Officer's signature date
unless otherwise specified.	
	APPROVALS	
(Signature)
(Date)
(Mail Code)
Work Assignment Manager
(Phone #)
Branch/Division Approval
(Funds are available from Division Allocation)
Project Officer, Nancy o. Livingstone
Contracting Officer, Margaret Milligan
                                                   OS-240
                                                   PM-214F
                             475-9339
                            475-8948
Signature:
Title:
                          CONTRACTOR'S ACCEPTANCE
             Date:

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CONTRACT NO.:     68-03-3450
CONTRACTOR:    ROY F HESTOfC
                                        WORK ASSIGNMENT NO.
                                        AMENDMENT NO.:	
                                        ACCOUNT NO.:	
                                        OCN :	
  PROGRAM AREA/ACTIVITY:
                                                                            J
                                                                            A
                           WORK ASSIGNMENT REQUEST
  TITLE:
  BRIEF DESCRIPTION AND PURPOSE:
  DELIVERABLES AND DUE DATES:
  SCOPE OF WORK REFERENCE (page and paragraph):
  LEVEL OF EFFORT:
  COST ESTIMATE:  _
  COMPLETION DATE:
  EFFECTIVE DATE: Date of contracting officer's signature
WORK ASSIGNMENT MANAGER:
Name: 	
Phone:  	
Mail Code: 	
                                 APPROVALS
                                                                  Dae
DIVISION DIRECTOR:
Name: 	
Phone:  	
Mail Code: 	
                                                                  Dele
PROJECT OFFICER:
Name:  Michael J. Cullen
Phone:  382-2131	
Mail Code:  05-240
CONTRACTING OFFICER:
Name:
Phone:   FTS 634-7739	
Mail Code: Contracts Management Division
                                                                   Date

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  CONTRACT NO.:
  CONTRACTOR:
    RQY
WORK ASSIGNMENT NO.
AMENDMENT NO.:	
ACCOUNT NO.:	
OCN :	
  PROGRAM AREA/ACTIVITY:
                          WORK PLAN APPROVAL
WORK PLAN APPROVED HOURS: 	
WORK PLAN APPROVED AMOUNT:	
WORK PLAN APPROVED, CONDITIONAL:
BRIEF DESCRIPTION OF CONDITIONAL APPROVAL
 EFFECTIVE  DATI: 0«tt of contracting offlc*r» signatur*
                                 APPROVALS
 WORK ASSIGNMENT MANAGER:
 Nam*: 	
 Phon*:  	
 M«ilCodt: 	
 DIVISION DIRECTOR:
 Nam*: 	
 Phon*:  	
 Mail Cod*: 	
 PROJECT OFRCet
 Name:  Michael J. Cullen
 Phont:
 Mall Cod*:
05-240
 CONTRACTING OFFICER:
 Nam*:
 Phon«:  FT^
 Mail Coda: Contracts Management Division

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                                KEMCQ 68-^8-0119
! TASK INSTRUCTION
j Name of Task
1
| Oriainal 	
1
DOCUMENT A
Modification
J
TID t A-
Date
L
Account & Appropriation Data:
Level of Effort:
Period of Performance:
Task Description:
Deliverables:
Contact:
 REQUESTS AND APPROVALS:
 Division Contact and Phone
 Division Approval Availablity of Funds
 Project Officer
 Contracting Officer
                              Date of Request
                              Date of Approval
                              Date of Approval
                              Date of Approval
  CONTRACTOR ACCEPTANCE
                    ESTIMATED COST:
 Signature
                           Date of Acceptance
 EVAUATION OF DELIVERABLE(S):
 Work completed by stated due date?
 Work met quality/quantity objectives?
 Received Project Officer:   	
                        Yes
                 Received by:
   No
 Accepted:
 Comments:
       Date
Accepted with Exception:
Div.  Contact & Date
_     Rejected: 	

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                                 KENCO 68-W8-0119
|   TASK INSTRUCTION DOCUMENT B
   Name of Task
        Original
Modification
                                    TID # B-
      Date
 Account & Appropriation Data:   CHOOOe    9TFA72C70Q
 Priority Code:
 Task Description:
OeliveraJbles:
 REQUESTS AND APPROVALS:
 Division Contact  and Phone
 Division Approval Availablity of Funds
 Project Officer
                               Date of Request
                               Date of Appro
                               Date of Approval
 CONTRACTOR ACCEPTANCE
 Date and Time In
                    ESTIMATED COST:
                   Date and Time Out
 Signature
                            Date of Acceptance
 EVAUATION OF DELIVERABLE{S):
 Work completed by stated due date?
 Work met quality/quantity objectives?
 Received Project Officer:  	
                         Yes
                 Received t»y:
    NO
 Accepted:
 Comments:
       Date
Accepted with Exception:
 Div.  Contact  & Date
	    Rejected:

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 &EPA
                 Designation and Appointment of Project Officer/
                Work Assignment Manager/Delivery Order Officer
                                 (For Other Than Small Purchases)
     Note: This form is not a Contracting Officer warrant. Delivery Order Officers and Administrative Delivery
     Order Officers require a warrant of Contracting Officer authority. Any request for a Delivery Order Officer
     warrant must be accompanied by the additional information required in Chapter 8 of the Contracts Manage-
     ment Manual.
 1» Name of Nominee
                                             b. Title
 c. Organization
                   d. Mail Code
e. Telephone
                                                                       f. Years of Contract Experience
 2. The nomination is for;

      D  Project Officer

      LJ  Work Assignment Manager

      LJ  Delivery Order Officer

      LJ  Administrative Delivery Order Officer

      LJ  Delivery Order Project Officer
                                             3. The Nominee Has:

                                               a. Completed the basic Project Officer Course

                                               b. Completed the Contract Administration Course

                                               c. Incorporated appropriate contract management
                                                 criteria tn position description and performance
                                                 standard. (If criteria have not keen incorporated.
                                                 they must be incorporated within 30 days of
                                                 appointment.)

                                               d. If the nominee has not completed the basic Pro-
                                                 ject Officer Course or the Contract Adminis-
                                                 tration Course, has a waiver or interim
                                                 certification been provided

                                               If the answer to items a. b. or c is "No." or the
                                               answer to item d is "No." attach an explanation)
                                         B
                                         D
                                         D
a
D
D

D
4. Estimated Dollar Amount of Contract, Work Assignment, or Delivery Order
 5 Nomination is for (Check one/


     LJ a new contract, work assignment, or delivery order entitled
     D
a change in the Project Officer. Work Assignment Manager, or Delivery Order Officer on Contract No.
     (if applicable, the work assignment no /delivery order no is
                                              Certification
       The undersigned nominee and requesting official certify that the designation of this
       nominee complies with the workload limitations and other requirements set forth in
       Chapter 7 of the Contracts Management Manual.
63 Signature of Nominee
                                                                            b. Date
 7a Signature of Requesting Official
   (Division Director or Higher)
                                  b Name and Title
                               c. Date
Ba Signature of Approval Official
   (Contracts Organnationl
                                  b Name and Title
                               c. Date
EPA Form 1900-65 (6-85)

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                            OERR CONTRACTOR EVALUATION
 Contractor:

 Contract Number:

 Work Assigrment Number and Title:

 Work Assigrment Manager:

 Project Officer:

 Ratings:     4  Excellent
              3  Very Good
              2  Average
              1  Poor
              0  Unsatisfactory

 I TECHNICAL PERFORMANCE
    Criteria;

       Level of creative contribution
       Effective application of relevant
           statutes/regulations/guidelines
       Resourcefulness
       Adherence to scope of work
       Effectiveness of project planning

    Overall Rating for Technical Performance;

    Narrative Evaluation:
Period Covered;
Ratings; (Circle one per criterion.)
3
3
3
3
3
2
2
2
2
2
1
1
1
1
1
0
0
0
0
0
II PERSONNEL ASSIGNED
    Criteria:
Ratings;
       Technical competence appropriate to project    4
       Comitment to the project                      4
       Effective interaction, responsiveness          4
       Appropriate mix of professional levels         4

    Overall rating for Personnel Assigned;            4

    Narrative evaluation:
          3
          3
          3
          3
2
2
2
2
1
1
1
1
0
0
0
0

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Ill DELIVERABLES/REPORTING
        Criteria:
 Ratings;
           Quality of product, thoroughness,
                adequate technical detail
           Minimal corrections/revisions required
           Quality assurance by Contractor
           Adherence to schedule

        Overall Rating for Deliverables/Reporting;

        Narrative Evaluation:
     4
     4
     4
3
3
3
2
2
2
1
1
1
0
0
0
 IV BUDGET
     Criteria:
        Cost effectiveness
        Efforts to keep within budget
        Early notification of potential overruns

     Overall Rating for Budget;

     Narrative Evaluation:
Ratings;

     4
     4
     4
3
3
3
2
2
2
1
1
1
0
0
0
 V OVERALL RATING FOR WORK ASSIGNMENT                43210

       Although this evaluation involves numerical ratings,  the overall rating
    for the work assignment need not be a strictly mathematical average. In
    considering the work assignment as a whole,  more weight should be given
    to areas I and III, Technical Performance and Quality of  Deliverables.
 VI

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                       CPAF CONTRACT INDIVIDUAL PERFORMANCE EVENT

 CONTRACT NO,
                                   CONTRACTOR
                                                                              TASK ORDER NO
 REPORTING ELEMENT
DATEU) OF REPORTED EVENT
 PERFORMANCE EVALUATION CATEGORY
 WAI CONTRACTOR NOTIFIED! CD »E»  D MO   •» WHOMT
                                                                             WMKNT
 DESCRIPTION OF PERFORMANCE EVENT
  0. OR -
                                  'SIGNATURE OF MONITOR
                                                                              DATE
 COORDINATOR'S ASSESSMENT
 ». 0, OR -
                                  SIGNATURE Of COODINATOR
6PA Pwrn 1900-41B (R.v. 6.79)
                                  PREVIOUS EDITION MAY BE. USED

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                                                     Appendix III
                "Inherently Governmental
     The following extract from a paper entitled "Legal Guidance
on the Prohibition of Contracting for Inherently Governmental
Functions" by A. G. Beyer, OGC/RTP, 1/5/89, discusses the meaning
of inherently governmental functions.
         Definition of "Inherently Governmental Funp^ion1*

             The Office of Management and Budget (OHB)  has issued
         its OMB Circular A-76 which establishes a Federal policy
         of relying on commercially available sources to provide
         commercial products and services.  Associated with this
         policy is a requirement that Federal agencies retain
         governmental functions in-house:

             Paragraph 5.b.  Retain Governmental Functions In-
             house.  Certain functions are inherently
             Governmental in nature, being so intimately related
             to the public interest as to mandate performance only
             by Federal employees.  These functions are not in
             competition with the commercial sector.  Therefore,
             these functions shall be performed by Federal
             employees.

     OMB Circular No. A-76 also provides the following definition:

             Paragraph 6.e.  A Governmental function is a function
             which is so intimately related to the public interest
             as to mandate performance by Government employees.
             These functions include those activities which
             require either the exercise of discretion in applying
             Government authority or the use of value judgment in
             making decisions for the Government.  Services or
             products in support of Government functions... are
             commercial activities and are normally subject to
             this circular.  Governmental functions normally fall
             into two categories:
             (1) The act of governing: i.e., the discretionary
             exercise of Governmental authority.  Examples include
             ... management of Government programs requiring value
             judgments as in ... [the] selection of program
             priorities; direction of Federal employees;....
             (2) Monetary transactions and entitlements,  such as
             tax collection and revenue disbursements,  control of
             the treasury accounts and money supply; and the
             administration of public trusts.  (Emphasis
             supplied.)  OMB Circular No A-76 dated August 4,
             1983.

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