FPA
United States
Environmental Protection
Agency
Administration And
Resources Management
(3401)
EPA220-B-94-012
October 1994
Federal Information Processing
(FIP) Resources Acquisition
Planning And Development Guide
r
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FEDERAL INFORMATION PROCESSING
(FIP) RESOURCES ACQUISITION
GUIDE
September 23,1994
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FIP Resource Acquisition Guide
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FIP Resource Acquisition Guide Preface
PREFACE
In March 1992, the Environmental Protection Agency's (EPA's) Inspector General
(IG) identified problems in the agency's procedures for acquiring and managing
Federal Information Processing (FIP) resources, particularly in the processes for
acquiring FIP support services. In the wake of these findings, the Office of Information
Resources Management (OIRM) committed to improving the agency's FIP acquisition
process. This guide provides guidance to EPA personnel on acquiring FIP resources
with an emphasis on acquisition by procurement.
The FIP Acquisition Guide is intended to address many of the deficiencies identified
by the IG and to strengthen the agency's overall process for acquiring FIP resources.
Effective acquisition and use of automated data processing equipment (ADPE) and
services is critical to achieving EPA's environmental goals and to implementing
essential agency business functions. The procedures established in the guide are
intended to ensure that EPA acquisitions of FIP resources are well planned, executed,
and comply with Federal and EPA Information Resources Management (IRM)
requirements.
This guide is being issued at a time when the agency is making a significant
investment in re-inventing critical business processes. OIRM is committed to this task
and has sought to build flexibility into the FIP approval process where appropriate. The
guide also provides for the delegation of OIRM authorities to each Assistant
Administrator's organization as a method of flattening and expediting the approval
process.
However, many of the requirements that control the acquisition of FIP resources
governmentwide are contained in the Brooks Act, General Services Administration
(GSA) regulations, and other critical Federal directives (e.g., Office of Management and
Budget [OMB] Circular A-130), and are not within EPA's discretion to modify. As GSA,
Congress, or other agencies modify their acquisition requirements, OIRM will work to
modify its process in kind. In the interim, this guide provides specific guidance for
developing, reviewing, and approving critical acquisition documentation in order to
facilitate the acquisition process. This is also done to simplify the process of working
with complex rules such as the Federal Information Resources Management Regulation
(FIRMR).
This guide was developed by OIRM's Oversight and Compliance Support Staff
(OCSS) with support from GSA's Federal Systems Integration and Management Center
(FEDSIM).
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FIP Resource Acquisition Guide Table of Contents
TABLE OF CONTENTS
Page
1. INTRODUCTION
Background 1-1
Objectives 1-2
Scope of this Guide 1-2
Relationship to EPA and Governmentwide Guidance 1-4
Suggestions for Using This Guide 1-4
2. FIP RESOURCES ACQUISITION ENVIRONMENT
Acquisition Legislation, Oversight Agencies, and Regulations 2-1
Federal Legislation 2-1
Oversight Agencies 2-1
Federal Regulations 2-2
The FAR/FIRMR 2-2
OMB Circulars 2-4
Federal Information Processing Standards and Guidance 2-5
EPA Regulations 2-5
FIP Resources Definition 2-5
FIP Resources Planning and Budgeting 2-9
Management Plans 2-9
FIP Resources Budgeting 2-11
Acquisition Delegations 2-12
Acquisition Sources 2-14
Acquisition Methods 2-14
Trail Boss Program 2-17
Organizational Support 2-18
Office of Acquisition Management 2-18
Office of Information Resources Management 2-18
Oversight and Compliance Support Staff 2-19
Office of Small and Disadvantaged Business Utilization 2-19
SIRMOs for Programs, Regions, and Administrative Organizations 2-20
3. ACQUISITION PROCESS OVERVIEW
Phase 1 - Initial Planning Phase 3-3
Phase 2 - Presolicitation Phase 3-4
Phase 3 - Solicitation Phase 3-5
Phase 4 - Source Selection Phase 3-5
Phase 5 - Contract Administration Phase 3-5
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FIP Resource Acquisition Guide Table of Contents
TABLE OF CONTENTS (Cont'd.)
Page
4. ACQUISITION PROCESS AND PROCEDURES
Phase 1 - Initial Planning Phase 4-6
Step 1 - Identify Information and FIP Resource Needs 4-7
Step 2 - Reconcile Needs with Existing Budgets,
Resources, and Plans; Update Plans as Needed 4-9
Step 3 - Document Mission Needs, Feasible
Solutions, and FIRMR Applicability 4-13
Step 4 - Obtain Internal Client Organization
Approvals to Proceed 4-21
Step 5 - Begin Acquisition Planning 4-23
Phase 2 - Presolicitation Phase 4-27
Step 6 - Determine Mission-Based Functional
Requirements and Analyze Alternative Solutions 4-27
Step 7 - Begin Implementation Planning 4-41
Step 8 - Determine Requirement for DPA 4-43
Step 9 - Prepare APR 4-46
Step 10 - Obtain Internal Client Organization
Approvals of APR Package 4-47
Step 11 - Obtain OIRM Approval of APR Package 4-48
Step 12 - Obtain OIRM Director Approval of APR Package 4-49
Step 13 - Obtain GSA Approval of APR Package 4-50
Phase 3 - Solicitation Phase 4-52
Step 14 - Prepare PRP 4-52
Step 15 - OIRM and OAM Review PRP 4-57
Step 16 - Issue Solicitation 4-59
Phase 4 - Source Selection Phase 4-60
Step 17 - Evaluate Proposals and Award Contract 4-60
Phase 5 - Contract Administration Phase 4-62
Step 18 - Track FIP Resource Costs and Report Status 4-62
Step 19 - Report DPA Status to GSA 4-63
FIP Resource Acquisition Guide iv
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FIP Resource Acquisition Guide Table of Contents
TABLE OF CONTENTS (Cont'd.)
Page
Appendix A Legal Acquisition Authorities A-1
Appendix B Regulatory and Reference Documents/Sources B-1
Appendix C Identifying FIP Support Services C-1
Appendix D Key References and Authorities by Step D-1
Appendix E Determining FIRMR Applicability E-1
Appendix F Instructions for Preparing an Agency Procurement Request F-1
Appendix G Contents of the Procurement Request Package G-1
Appendix H Acquisition of FIP Resources by Small Purchase H-1
Appendix I Points of Contact 1-1
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FIP Resource Acquisition Guide List of Exhibits
LIST OF EXHIBITS
Page
2-1 FIP Resources 2-7
2-2 Examples of FIP Support Services 2-8
3-1 Acquisition Life Cycle 3-2
4-1 Acquisition Phases and Steps 4-2
4-2 Acquisition Activities and Responsibility 4-4
4-3 Phase 1: Initial Planning 4-6
4-4 FIRMR Applicability Decision Flow Chart for Acquisitions by Contract 4-19
4-5 Phase 2: Presolicitation 4-28
4-6 Phase 3: Solicitation 4-52
4-7 Phase 4: Source Selection .75 4-60
4-8 Phase 5: Contract Administration 4-62
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FIP Resource Acquisition Guide
List of Acronyms
LIST OF ACRONYMS
AA Analysis of Alternatives
ADP Automated Data Processing
ADPE Automated Data Processing Equipment
AMPB Architectural Management and Planning Branch
APR Agency Procurement Request
AR Approval Requirement
CAP Contractor-Acquired Property
CBD Commerce Business Daily
CBI Confidential Business Information
CD-ROM Compact Disk-Read Only Memory
CICA Competition in Contracting Act
CMM Contracts Management Manual
CO Contracting Officer
D&F Determination and Findings
DoD Department of Defense
DOPO Delivery Order Project Officer
DSO Designated Senior Official
DPA Delegation of Procurement Authority
DR Documentation Requirement
FIP Resource Acquisition Guide ix
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FIP Resource Acquisition Guide
List of Acronyms
LIST OF ACRONYMS (Cont'd.)
EBBS Electronic Bulletin Board Service
EOF Executive Office of the President
EPA Environmental Protection Agency
FAR Federal Acquisition Regulation
FED-STDS Federal Telecommunications Standards
FEDSIM Federal Systems Integration and Management Center
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FIP Federal Information Processing
FIPS Federal Information Processing Standards
FIPS PUB Federal Information Processing Standards Publication
FIRMR Federal Information Resources Management Regulation
FISSP Federal Information Systems Support Program
FMSD Facilities Management and Services Division
FMSS Financial Management Systems Software
FSS Federal Supply Service
FTE Full-Time Equivalent
FTS Federal Telephone Services
GAO General Accounting Office
GFI Government-Furnished Information
FIP Resource Acquisition Guide x
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FIP Resource Acquisition Guide List of Acronyms
LIST OF ACRONYMS (Cont'd.)
GFP Government-Furnished Property
GPO Government Printing Office
GSA General Services Administration
GSBCA GSA Board of Contract Appeals
IAG Interagency Agreement
IG Inspector General
IGCE . Independent Government Cost Estimate
IP Implementation Plan
IRM Information Resources Management
IT Information Technology
ITF Information Technology Fund
JOFOC Justification for Other than Full and Open Competition
LAN Local Area Network
MAS Multiple Awards Schedule
MES Management and Evaluation Staff
WINS Mission Needs Statement
NASA National Aeronautics and Space Administration
NDPD National Data Processing Division
NIST National Institute of Standards and Technology
FIP Resource Acquisition Guide xl
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FIP Resource Acquisition Guide List of Acronyms
LIST OF ACRONYMS (Cont'd.)
NTIS National Technical Information Service
OAM Office of Acquisition Management
OARM Office of Administration and Resources Management
OFPP Office of Federal Procurement Policy
OCSS Oversight and Compliance Support Staff
OGC Office of General Council
OIG Office of Inspector General
OIRM Office of Information Resources Management
OMB Office of Management and Budget
ORD Office of Research and Development
OSDBU Office of Small and Disadvantaged Business Utilization
OSS On-Line Schedule System
OTA Office of Technical Assistance
P&CV Performance and Capability Validation
PC Personal Computer
PO Project Officer
POTS Purchase of Telecommunications Services
PR Processing Requirement
PRP Procurement Request Package
FIP Resource Acquisition Guide xii
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FIP Resource Acquisition Guide List of Acronyms
LIST OF ACRONYMS (Cont'd.)
PRA Paperwork Reduction Act
QA Quality Assurance
RA Requirements Analysis
RCRA Resources Conservation and Recovery Act
RFP Request for Proposal
RKR Recordkeeping Requirement
RTP Research Triangle Park
SIRMO Senior Information Resources Management Official
SOW Statement of Work
SRO Senior Resource Official
TEP Technical Evaluation Panel
TSC Telecommunications Support Contracts
TSCA Toxic Substances Control Act
WAM Work Assignment Manager
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Chapter 1 Introduction
Background
1. INTRODUCTION
NOTES
Laws
The Environmental Protection Agency (EPA) was established
in 1970 to protect and enhance the United States environment by
controlling and abating air, water, solid waste, chemical, and
other toxic pollutants. In accomplishing its mission, EPA has
acquired a wide range of Federal Information Processing (FIP)
resources to support its research, monitoring, standard setting,
and enforcement activities.
Acquisition of these resources is a long and time consuming
process. This Guide has been developed by the Office of
Information Resources Management (OIRM) to assist EPA
personnel in acquiring FIP resources in a timely and efficient
manner.
Background
FIP resources have become a mainstay in the operation and
execution of EPA's environmental goals. Virtually every
organization within EPA relies on FIP resources to conduct day-
to-day operational mission and business functions. During a
review of EPA's FIP resources, the EPA Inspector General (IG)
identified procedural problems with acquiring and managing FIP
resources, particularly acquiring FIP support services. OIRM is
addressing these problems and is committed to improving the
agency's FIP resources acquisition process.
The majority of requirements that dictate FIP resource
acquisition activities are contained in the Brooks Act, the Federal
Acquisition Regulation (FAR) (Chapter 1, Title 48, of the United
States Code), the Federal Information Resources Management
Regulation (FIRMR), and other critical Federal and General
Services Administration (GSA) directives. These regulatory
documents prescribe specific acquisition activities and analyses
and are not within EPA's authority to change.
OIRM is working within the framework of these Federal
regulations to strengthen and streamline the EPA acquisition
process. OIRM's Oversight and Compliance Support Staff
FIP Resource Acquisition Guide 1-1
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Chapter 1 Introduction Objectives
NOTES (OCSS) has developed the FIP Resources Acquisition Guide to
address many of the deficiencies identified by the IG.
This guide effectively integrates activities necessary to
acquire FIP resources in a timely and efficient manner. The
acquisition process presented in this manual is organized into a
series of five cyclic phases: Initial Planning, Presolicitation,
Solicitation, Source Selection, and Contract Administration.
Specific procedures and activities required for an EPA
acquisition are divided into 19 steps within these phases. These
steps guide the EPA Project Officer (PO) from the initial
planning to contract administration.
Objectives
The primary objective of this guide is to provide EPA
personnel involved in the acquisition process with the basic
information, procedures, and points-of-contact necessary to
acquire FIP resources, either through a dedicated FIP
procurement or as an embedded component in a larger mission-
based contract. In addition, the information and procedures in
the guide are intended to ensure that EPA acquisitions of FIP
resources comply with Federal and EPA acquisition
requirements.
The guide emphasizes the procedures and requirements for
acquiring FIP resources through new contracts, since successful
contracting is critical to EPA's mission of protecting the
environment. However, the guide also steers acquisition
personnel through FIRMR requirements that are intended to
ensure that all appropriate acquisition alternatives are
considered by the client and that the acquisition process results
in the best service and performance outcome for the agency.
Scope of this Guide
This guide focuses on the basic procedures and documents
required of EPA organizations when acquiring FIP resources,
but does not attempt to address every detail of the acquisition
life cycle. The range of FIP resource acquisition issues is broad
and often complicated, and individual organizations'
FIP Resource Acquisition Guide 1 -2
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Chapter 1 Introduction
Scope of Manual
NOTES
requirements vary greatly. A single guide could not adequately
address every situation.
The procedures described in Chapter 4 implement FIP
acquisition requirements specifically prescribed in Federal and
EPA policies and regulations. These procedures describe the
basic processes, documentation, recordkeeping, and approval
requirements of the acquisition process, with emphasis on
acquisition by new contract. Rather than quoting large portions
of the FAR, FIRMR, and other reference sources, the
appropriate sources are referenced for each step in the process
in Appendix D for more detailed information and guidance.
This guide primarily addresses acquisition of FIP resources
through contracting. However, other methods of acquiring RIP
resources are acknowledged including use of in-house
resources, sharing FIP resources through use of an existing
contract, and interagency agreements. In the future, OIRM
plans to expand the guide to include chapters on other
acquisition methods such as developing interagency
agreements for acquiring FIP resources.
The initial steps in the process described by this guide
are to be applied to all FIP acquisitions regardless of the
acquisition method and source used (i.e., contracting,
in-house, or interagency). Additional guidance on the
interagency agreement process is contained in EPA's
Interagency Agreement Policy and Procedures Compendium.
The detailed procedures and documents developed by other
organizations, such as OIRM and the Office of Acquisition
Management (OAM), are not within the scope of this guide.
Neither does it provide detailed procedures for "small purchase"
($25,000 or less) type acquisitions. Primary policy and
guidance for small purchases are contained in FAR Part 13 and
Chapter 2 of the EPA Contracts Management Manual (CMM).
Appendix H contains the basic documentation requirements for
small purchases, as well as additional references.
FIP Resource Acquisition Guide 1 -3
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Chapter 1 Introduction
Guidance
NOTES
Regulations
Relationship to EPA and
Governmentwide Guidance
The procedures and guidance provided in this guide conform
to FAR, FIRMR, applicable Office of Management and Budget
(OMB) Circulars, Federal Information Processing Standards
Publications (FIPS PUBs), GSA pamphlets, and EPA Directives,
Regulations, Manuals, and Handbooks.
A list of regulations, policies, standards, and guidance
referenced in this document, or identified as being pertinent to
EPA acquisitions, is located in Appendix B.
Suggestions for Using This Guide
The approach, procedures, and activities described in this
guide comply with Federal and EPA regulatory documents. This
guide is not intended to replace or supersede any mandated or
well established acquisition planning approach in effect in EPA
offices, but is presented as a guide to developing and/or
enhancing an approach when deemed necessary by client
management.
The term "client" is used throughout the document to indicate
any EPA individual, usually a PO, that initiates, submits for
approval, or manages a FIP resources acquisition. Unless
stated otherwise (e.g., client management or organization), the
guide uses the terms "client," "client PO," and "PO"
synonymously.
Chapter 1 of this guide documents the guide's objectives,
scope, and orientation. Following the introduction in Chapter 1,
the reader should review Chapter 2 which describes the Federal
environment in which FIP resources are acquired. The reader
should understand the role of Federal and EPA legislation,
oversight organizations, and regulations, specifically the
contrasting focus of the FAR and the FIRMR. The chapter
clearly defines and gives examples of FIP resources and
summarizes EPA management and budget plans and processes
related to acquiring resources. Additionally, the chapter reviews
GSA's delegation of procurement authority (DPA) process and
FIP Resource Acquisition Guide 1 -4
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Chapter 1 Introduction Usage
NOTES levels, the various sources for acquiring FIP resources, and EPA
organizations intricately involved in the acquisition process.
Appendix A lists Federal legislation and oversight organizations
which govern FIP acquisitions. Federal and EPA acquisition
regulations, policies, and guidance are listed in Appendix B
along with instructions on obtaining the documents or
references. Appendix C provides guidance on identifying FIP
support services.
Chapter 3 presents a high-level overview of the acquisition
process, discussing the five phases and the general objective(s)
of each phase. This overview provides the reader an
introduction to the overall process and enables the reader to
ascertain the flow of events comprising the acquisition process.
The specific phases and steps of the EPA acquisition process
are detailed in Chapter 4. The process presented in this model
is geared toward acquisition by contract, however, the initial
planning and analyses conducted during the early stages is
| relative to all acquisitions, regardless of the method or source.
The reader is encouraged to review the entire process and then
focus on the steps and activities which pertain to their applicable
method of acquisition. Appendix D lists references for each
step, enabling the reader to further research the activities
involved in the step.
The FIRMR dictates specific activities and analyses for FIP
acquisitions, therefore, the reader must determine whether or
not the FIP acquisition being undertaken falls within the purview
of the FIRMR. Appendix E provides assistance in determining
the applicability of the FIRMR to specific acquisitions. Appendix
F contains instructions for preparing an Agency Procurement
Request (APR) to obtain a DPA from GSA. Detailed information
on the contents of a Procurement Request Package (PRP) are
listed in Appendix G.
Appendix H provides a brief overview of the "small purchase"
process for acquiring FIP resources. Appendix I contains
points-of-contact for further information.
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Chapter 1 Introduction
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FIP Resource Acquisition Guide 1 -6
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Chapter 2 FIP Resources Acquisition Environment
Legal Environment
2. FIP RESOURCES ACQUISITION ENVIRONMENT
NOTES
Laws
Acquiring FIP resources in the current Federal environment is
a long, tedious endeavor complicated by the plethora of
regulations, varied terminology, pre-acquisition planning
activities, and agency-specific requirements and procedures.
This chapter documents the Federal environment applicable to
FIP resource acquisitions, specifically, highlighting applicable
regulatory documents and contrasting the focuses of the FAR and
FIRMR; defines and distinguishes categories of FIP resources;
provides a high-level overview of related EPA management and
budgetary plans; and reviews the GSA delegation of procurement
authority process. Additionally, the chapter describes the various
methods of acquiring FIP resources and the EPA organization
available for assistance in acquiring these resources.
Acquisition Legislation, Oversight
Agencies, and Regulations
Federal acquisitions are strictly regulated and affected by
numerous Congressional, GSA, OMB, and EPA legislation,
committees, agencies, regulations, policies, and guidance.
Federal Legislation
The Federal legislation that directly affects the acquisition of
FIP resources include the Brooks Act, the Warner Amendment,
and the Paperwork Reduction (and its reauthorization),
Competition in Contracting, Computer Security, Office of Federal
Procurement Policy (OFPP), and Privacy Acts. These laws are
summarized in Appendix A.
Oversight Agencies
Congressional legislation has delegated primary authority for
overseeing various aspects of FIP resource acquisitions to GSA,
OMB, OFPP, the General Accounting Office (GAO), and the
National Institute of Standards and Technology (MIST). Specific
responsibilities are listed in Appendix A.
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Chapter 2 FIP Resources Acquisition Environment
FAR/FIRMR
NOTES
Regulations
Federal Regulations
The most significant regulations governing FIP resource
acquisitions are the FAR and the FIRMR. In addition to these
two regulations, the Federal government has published a wide
range of regulatory and guidance documents to direct and assist
Federal acquisitions. Appendix B contains a list of acquisition-
related documents cited in this guide and/or provided as
reference or guidance.
The FAR/FIRMR
The FAR, issued in 1984, is the primary regulation affecting
Federal agencies acquiring supplies and services with
appropriated funds. The FAR prescribes Governmentwide
regulations for all Federal acquisitions and is issued under the
joint authority of GSA, the Department of Defense (DoD), and
the National Aeronautics and Space Administration (NASA).
The FAR implements the Competition in Contracting Act (CICA).
FAR Part 39.001 states that "in acquiring information
resources, acquisition personnel shall follow the policies and
procedures contained in the FAR except in those areas where
the FIRMR describes special policies, procedures, provisions, or
clauses".
The FIRMR, issued in 1984 and reissued in 1991, is the
primary Governmentwide regulation for acquiring, managing,
and using FIP resources. Issued by GSA with policy direction
from OMB, the FIRMR governs Federal agencies' activities in
the following areas:
• Acquisition, management, and use of FIP resources
• Issuance of solicitations and contracts requiring the
delivery of FIP resources to the Government or, under
specified conditions, the use by a contractor of FIP
resources
• Creation, maintenance, and use of Federal records
FIP Resource Acquisition Guide 2-2
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Chapter 2 FIP Resources Acquisition Environment FAR/FIRMR
r NOTES The FIRMR helps ensure that information resources are
> j acquired, managed, and used to improve service delivery and
! \ program management, increase productivity, reduce waste and
i , fraud, and minimize paperwork burdens. It contains provisions
i , that cover a range of Information Resources Management (IRM)
; | areas including IRM planning, records management, information
i security, and FIP acquisition requirements. With regard to
i acquisitions, the FIRMR establishes a framework and process
for planning, analyzing, acquiring, and managing information
resources. This process specifies activities such as conducting
i requirements analyses, identifying and evaluating alternatives,
' and planning and implementing the acquisition. The FIRMR
i refers to these three activities as the Requirements Analysis
i (RA), Analysis of Alternatives (AA), and Implementation Plan
! (IP).
) i
! Although both the FAR and FIRMR deal with acquisitions, the
i | focus of the two documents is different. The FAR Part 2,
, Subpart 2.101 defines acquisition as acquiring, by contract
with appropriated funds, supplies or services (including
1 construction) by and for the use of the Federal Government
through purchase or lease, whether the supplies or services are
already in existence or must be created, developed,
demonstrated, and evaluated.
i
i
According to the FAR, acquisition begins at the point when an
; agency's needs are established and includes the description of
1 requirements to satisfy the needs, solicitation and selection of
sources, award of contracts, contract financing, contract
, performance, contract administration, and those technical and
, management functions directly related to the process of fulfilling
the agency's needs by contract.
In FIRMR Part 201 -20, the definition of acquisition:
• Consists of a series of steps beginning with the RA and '
i ending with the implementation of the most advantageous
; , alternative to satisfy the requirement
• Includes obtaining FIP resources both from sources
i external to the agency and through in-house sources
FIP Resource Acquisition Guide 2-3
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Chapter 2 FIP Resources Acquisition Environment
OMB Circulars
NOTES
Under the FIRMR definition, an acquisition may involve
using in-house resources, contracted resources, other
agency resources, developing FIP resources (software,
hardware, or systems), or a combination of these to meet an
agency's need.
Contrasting the two regulations, the FAR addresses
acquisition (i.e., procurement) by contracting, whereas the
FIRMR addresses acquiring and managing FIP resources
regardless of source. The term "acquisition" is used in this
guide in the broader context of the FIRMR definition. Where
this guide focuses on acquisitions involving a contract, the
terms "procurement," "contract," or "acquisition by
contract" are used for clarity.
When FIP resources are acquired by contracting, the FIRMR
must be used in conjunction with the general procurement and
contracting regulations contained in the FAR. The FAR is
written primarily for Contracting Officers (COs) and contains
rules that pertain to the procurement process. The FIRMR is
written for all individuals who deal with FIP resources and
contains one Part (201-39) that has rules on the procurement
process. When acquiring FIP resources, if a conflict
between FIRMR Part 201-39 and the FAR, the FIRMR
generally takes precedence.
Guidance for determining FIRMR applicability to a specific
solicitation or contract is provided in Chapter 4 and Appendix E.
OMB Circulars
The Paperwork Reduction Act of 1980, as amended (PRA),
designated OMB as being responsible for providing leadership
and coordination of IRM, specifically:
• Developing and implementing a comprehensive set of IRM
policies, principles, standards, and guidelines
• Promoting the use of information technology (IT) to
improve the use and dissemination of information by
Federal agencies
FIP Resource Acquisition Guide 2-4
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Chapter 2 FIP Resources Acquisition Environment EPA Regulations
NOTES To satisfy these responsibilities, OMB issued numerous OMB
Circulars that provide Govemmentwide policy on FIP
1 acquisitions. OMB Circulars pertinent to FIP resource
| acquisition are listed in Appendix B.
Federal Information Processing Standards and
Guidance
: | NISI develops Federal Information Processing Standards
1 (FIPS) and issues FIPS PUBs as guidance and information
: documents on specific areas or to detail specifications for FIPS.
; ! FIPS PUBs relating to specific documentation requirements for
i FIP resource acquisitions are listed in Appendix B.
} ,
\ ! EPA Regulations
i i
| ' EPA has published numerous manuals, handbooks,
: guidelines, and regulations^which mandate specific activities,
detail processes, outline programs, and provide guidance. This
; guide does not supersede any activities mandated by these
: documents but is designed to complement these regulations and
publications. In particular, this guide expands on the EPA FIP
Resource Acquisition Interim Guidance dated April 22,1994.
EPA regulatory and policy documents referenced in this guide
are listed in Appendix B.
FIP Resources Definition
i i
The term FIP resources encompasses a wide range of
* ' equipment, software, and related services. FIRMR Subpart
; 201-4.001 defines FIP resources as "automated data processing
equipment (ADPE) as defined in Public Law 99-500,..." and
! "any equipment or interconnected system or subsystem of
equipment that is used in the automatic acquisition, storage,
manipulation, management, movement, control, display,
switching, interchange, transmission, or reception of data or
information - (1) by a Federal agency; (2) under a contract with
: a Federal agency that requires the use of such equipment; or
[ (3) requires the performance of a service or the furnishing of a
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Chapter 2 FIP Resources Acquisition Environment FIP Definition
NOTES product that is performed or produced making significant use of
such equipment."
The definition also "...includes -- (1) computers; (2) ancillary
equipment; (3) software, firmware [computer programs that are
embodied in a physical device that forms part of the equipment;
e.g., a chip, board], and similar procedures; (4) services,
including support services; and (5) related resources as defined
by regulations issued by the Administrator for General
Services." Also addressed in the FIRMR (Subpart 201-1.002
and Bulletin A-1, Attachment D) is "embedded FIP equipment."
Chapter 4, Step 3, discusses the issue of embedded equipment
relative to the FIRMR applicability to FIP resources.
The FIRMR categorizes FIP resources as equipment,
software, services, support services, maintenance, related
supplies, and systems (any organized combination of the
previous six categories). FIRMR Bulletin A-1, which includes
detailed definitions and examples of the various categories of
FIP resources, incorporates maintenance in the support services
category. As a result, this guide addresses FIP resources in
terms of five basic categories of equipment, software, services,
support services, and related supplies. Exhibit 2-1 defines
these five categories, as contained in FIRMR Bulletin A-1,
Attachment A, and provides examples of each category.
GSA does not require that a DPA be obtained to acquire
FlP-related supplies. Therefore, when discussing policies
and procedures pertaining to APRs and DPAs, this guide
excludes supplies and addresses only the equipment,
software, services, and support services categories.
Terms such as equipment, software, and supplies and their
relationship to data processing are generally well understood.
Because they are tangible automated data processing (ADP)
commodities, their status as FIP resources is clear. However,
the terms services and support services are not as easily
differentiated. Exhibit 2-2 delineates FIP support services and,
when used in conjunction with Exhibit 2-1, clarifies the
distinction between services and support services.
FIP Resource Acquisition Guide 2-6
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Chapter 2 FIP Resources Acquisition Environment
PIP Resources
CATEGORIES AND DEFINITIONS*
EXAMPLES
Equipment: Any equipment or
interconnected system or subsystems of
equipment used in the automatic
acquisition, storage, manipulation,
management, movement, control, display,
switching, interchange, transmission, or
reception of data or information.
Data processing equipment
Switching equipment
Ancillary equipment
Computers
Telecommunications equipment and
networks
Software: Any software, including
firmware, specifically designed to make
use of and extend the capabilities of FIP
equipment.
Software designed to use FIP
equipment
Firmware
Common-use software
Services: Any service, other than FIP
support services, performed or furnished
by using FIP equipment or software.
Teleprocessing
Local batch processing
Electronic or voice mail
Centrex
Packet switching
Support Services: Any commercial non-
personal services, including
maintenance, used in support of FIP
equipment, software, or services.
FIP resource management support
services
FIP resource technical support
services
FIP resource acquisition support
services
FIP resource clerical support services
Maintenance of FIP equipment and
software
Supplies: Any consumable item
designed specifically for use with FIP
equipment, software, services, or support
services.
Supplies for maintenance, equipment,
or software
Floppy, Compact Disk-Read Only
Memory (CD-ROM), and optical disks
Cables, wires, and cartridges
Definitions are taken from FIRMR Bulletin A-1, Attachment A.
FIP RESOURCES
Exhibit 2-1
FIP Resource Acquisition Guide 2-7
-------
Chapter 2 FIP Resources Acquisition Environment FIP Support Services
PIP Resource Management Support Services
- IRM Planning - Systems Analysis and Design
- Requirements Analysis (RA) -- Conversion Study
- Analysis of Alternatives (AA) -- Risk Assessment
- Security - Capacity Management
- Quality Assurance (QA) - Training
- Network Analysis and Design
FIP Resource Technical Support Services
-- Facilities management
(including operation of Government-furnished FIP equipment)
- Conversion J
- Computer output microfilming
- Network installation and/or operation
- Network management
- Computer performance evaluation performed by contractors
- Custom software development
- Performance and capability validation (P&CV)
FIP Resource Acquisition Support Services
- Specifications/statement of work (SOW) development
-- Source selection material development
FIP Resource Clerical Support Services
- Source data entry
Maintenance of FIP Equipment and Software
- Equipment diagnostic and repair services
- Field modifications to FIP equipment
- Modifications and upgrades to FIP software
EXAMPLES OF FIP SUPPORT SERVICES
Exhibit 2-2
FIP Resource Acquisition Guide 2-8
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Chapter 2 FIP Resources Acquisition Environment
Plans/Budget
NOTES
To assist in determining whether a specific task is a FIP or
non-FIP resource, the purpose and intent of the task should be
examined. In identifying FIP support services, it is useful to
focus on the task requirements, labor categories, and
deliverables. Is the task related to FIP, or does it merely make
use of a FIP resource, such as a personal computer (PC), as a
tool to perform a non-FIP task? GSA recognizes that many
routine tasks today are performed using automated tools like
PCs. Just because a task involves the use of an automated
tool, that task is not automatically a FIP support service
resource. Examples of non-FIP tasks^that may use computers
and software are composing business correspondence or
performing scientific analyses.
More extensive information regarding FIP resources,
including definitions, examples, and information on applicability,
policy, and exceptions can be found in the attachments to
FIRMR Bulletin A-1. Appendix C also provides guidance for
identifying FIP support services. This guidance is tailored to
EPA's scientific and regulatory environment and should
assist the reader in distinguishing FIP support services and
non-FIP resources.
FIP Resources Planning and Budgeting
Acquiring FIP resources is not a stand-alone process. Just
as each individual acquisition has a life cycle, it, in turn, is a
component in the overall agency IRM life cycle. This chapter
presents an overview of the planning and budgeting context
within which FIP resource acquisitions must take place and
provides a basis for technical staff and POs to better understand
the acquisition requirements established by the FAR*and
FIRMR.
Management Plans
EPA develops and maintains both an Agency Strategic and
Multiyear IRM Implementation Plan to satisfy Federal
requirements for addressing and projecting future FIP resource
needs. The PRA of 1980 requires Executive agencies to
develop and annually revise a five-year plan for meeting their IT
FIP Resource Acquisition Guide 2-9
-------
Chapter 2 FIP Resources Acquisition Environment Plans
NOTES needs. OMB Circular A-130 implements the PRA requirement
for Executive agencies to establish multiyear planning
processes for acquiring and operating IT.
The Agency IRM Strategic Plan articulates EPA's overall
IRM mission, vision, and goals. It outlines the strategies to be
undertaken to accomplish the goals. This is a high-level
statement of direction which guides investment in and
management of FIP resources. The IRM Strategic Plan
establishes the basis for each component organization's (e.g.,
Assistant Administratorship's) Multiyear IRM Implementation
Plan. The agency's Executive Steering Committee establishes
the Agency IRM Strategic and Multiyear Plans. Each
organization's Senior Information Resources Management
Official (SIRMO) is responsible for establishing IRM plans for
their organization.
The Multiyear IRM Implementation Plan demonstrates how
well individual IRM activity plans fit together to meet the overall
mission-related needs of the agency. Multiyear Plans:
• Define the objectives, projects, and initiatives necessary
to implement the strategies in the strategic plan
• Examine current areas of FIP resource applications
• Identify the future resources needed to carry out projects
and initiatives and serve as the basis for budget requests
• Identify costs associated with technology and services
Tactical Plans are developed to identify, schedule, manage,
and control the tasks necessary to accomplish individual
projects and initiatives identified in the Multiyear Plan. Tactical
planning may address any type of activity (e.g., an office
reorganization, a management study, or a FIP resources
acquisition). The tactical plan defines the work to be completed
and resources to be used within a fiscal year.
In the context of managing FIP resources, an activity may be
quite broad in scope. For example, one IRM activity defined as
"software modernization" might include all tasks associated with
FIP Resource Acquisition Guide 2-10
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Chapter 2 FIP Resources Acquisition Environment
Budget
NOTES
Budget
the modernization of software to include code conversion and
software improvement. Another activity may be more narrow in
scope, such as establishing a data element dictionary/directory
or acquiring specific FIP equipment or services.
Additional FIP resources required to accomplish initiatives
identified in the Multiyear Plan may be identified during
development of tactical plans. Tactical plans are developed by
the staff of individual Program Offices.
FIP Resources Budgeting
The budget process begins long before the fiscal year for
which the budget is formulated. OMB requires agencies issue a
"call for estimates" requesting budget input from their
organizations approximately 12 months prior to the fiscal year in
question. For example, a call issued in October of 1994 is for
Fiscal Year 1996. Because of the extensive budget lead time
required, organizations must do strategic and multiyear
implementation planning to clearly define their FIP resource
requirements and the budget impact of those requirements
before the call for estimates.
To accomplish this, each agency organization must:
• Examine strategic, multiyear, and tactical plans to identify
and/or reassess those information needs and associated
FIP resource requirements that will require funding in the
fiscal year(s) for which budgeting is taking place
• Use appropriate techniques to identify and/or reassess
any shortfalls in capacity or bottlenecks that may adversely
affect services and/or budgets for augmenting or replacing
ADPE, software, and/or systems
• Perform requirements and economic analyses to provide a
sound basis for estimated budget figures
All organizations should incorporate planned acquisitions in
the regular budget cycle. If this is not done, then the acquisition
process may be lengthened substantially until funds become
available.
FIP Resource Acquisition Guide 2-11
-------
Chapter 2 FIP Resources Acquisition Environment Delegations
NOTES Technology and cost projections based on presolicitation
activities such as RAs and AAs should be reviewed at critical
points throughout the acquisition process to accommodate
technological advances and price changes.
Acquisition Delegations
The Brooks Act (Public Law 89-306,1965) assigned
exclusive authority to GSA to purchase, lease, and maintain FIP
resources for Executive branch agencies. GSA re-delegates
authority to acquire FIP resources to Federal agencies such as
EPA via DPAs. GSA has three types of DPAs:
• Specific Acquisition Delegations - Specific acquisition
delegations are granted by GSA to cover individual
acquisitions not covered under a specific agency or
regulatory delegation. The specific acquisition delegation
is almost always the method used by GSA to grant EPA
authority to acquire FIP resources which exceed
regulatory delegation. This type of delegation is obtained
by submitting an APR to GSA requesting authorization to
acquire FIP resources by contract.
• Specific Aaencv Delegations - Specific agency
delegations are granted only after GSA performs an
Information Resources Procurement and Management
Review and finds that the agency's performance merits a
higher delegation threshold than the regulatory
delegation.
• Regulatory Delegations - The existing regulatory
delegation defined in FIRMR Subpart 201-20.305 allows
Federal agencies to procure FIP resources directly
without prior approval from GSA if:
0 The dollar value of any individual type of resource (with
the exception of FIP-related supplies) including all
optional quantities and periods over the life of the
contract, does not exceed $2.5 million ($250,000 for a
specific make and model specification or for
requirements available from only one responsible
FIP Resource Acquisition Guide 2-12
-------
Chapter 2 FIP Resources Acquisition Environment
Delegations
NOTES
source) and either paragraph (a)(1)(i), (a)(1)(ii), or
(a)(1)(iii) in FIRMR Subpart 201-20.305 applies (these
paragraphs refer to telecommunications within the
scope of Federal Telephone Services [FTSJ-2000
services or GSA's Consolidated Local
Telecommunications Services Program).
0 The agency is procuring financial management systems
software and services and support related to
implementing such software by using the GSA Financial
Management Systems Software (FMSS) mandatory
multiple awards schedule (MAS) contracts.
0 The agency is procuring FlP-related supplies (defined
in Exhibit 2-1) regardless of cost.
If a procurement exceeds the $2.5 million or $250,000
cost thresholds in any one of the four remaining FIP
resource categories, over the life of the contract, the FIRMR
requires the agency to have a specific agency delegation or
specific acquisition delegation. This applies to new
contract acquisitions and to modifications for additional
expenditures under existing contracts.
When other than the regulatory delegation is required, EPA
must submit an APR to obtain an alternate DPA from GSA,
thereby increasing the regulatory threshold for one or more FIP
resource categories. The specific acquisition delegation is the
type most frequently obtained by EPA. This type of DPA applies
only to the contracts) cited in the APR and authorizes EPA to
procure FIP resources up to the new dollar threshold only on
that contract. The term DPA used throughout the remainder of
this guide refers to a specific acquisition delegation, unless
indicated otherwise.
FIP resource requirements must not be fragmented into
separate procurements in an attempt to circumvent the DPA
thresholds stated in the FIRMR. This contracting practice
violates Federal acquisition regulations and could affect the
amount of authority EPA is delegated.
FIP Resource Acquisition Guide 2-13
-------
Chapter 2 FIP Resources Acquisition Environment Sources/Methods
NOTES Acquisition Sources
Acquiring FIP resources in accordance with the FIRMR can
be accomplished through numerous sources. Unlike the FAR
which focuses on acquisition by contract, the FIRMR addresses
acquiring resources regardless of the source. These sources
include in-house sources, external sources (contracts, other
agencies), development, or a combination of these. The FIRMR
requires agencies to examine these various sources in
determining the best method of acquisition. In general, the
"best" acquisition method for any given FIP resource is the one
which enables EPA to meet system performance requirements
and specifications at the lowest cost within the shortest possible
time.
In some instances, the FIRMR mandates acquisition methods
when obtaining certain FIP resources. For example, at a
number of locations in the United States, GSA requires agencies
to use consolidated local telecommunications service unless
such consolidated service cannot meet an agency's
requirements. Aside from such regulatory constraints, however,
the most desirable acquisition method for any given FIP
resource is determined on a case-by-case basis after
consideration and analysis of the various methods.
Acquisition Methods
The various methods to be considered when acquiring FIP
resources are listed below. The order in which these are
presented does not signify preference or priority over any other
method. However, all other feasible acquisition methods should
be adequately considered before beginning a new (contract)
procurement. Specific FIRMR references for each method are
listed in Appendix D.
• Resource Sharing - Resource sharing allows EPA to use
another agency's FIP resources to meet specific needs,
e.g., using one of the Federal Data Processing Centers to
process personnel data. Resource sharing is frequently
done on a "fee-for-service" basis. The method for this is
normally an interagency agreement (IAG).
FIP Resource Acquisition Guide 2-14
-------
Chapter 2 FIP Resources Acquisition Environment Methods
NOTES * In-House - Using existing EPA FIP resources, training
existing personnel, or hiring additional personnel should
be considered as a means of satisfying requirements
(e.g., excess equipment, in-house computer programming
staff).
• New Procurement - When other options are not feasible
or appropriate, a new contract may be considered. Types
of contracts include sealed bid, negotiated, and small
purchase. Sealed bid contracts are competitive bids with
the contract awarded to the bidder who meets the
requirements and is most advantageous to the
Government. Negotiated contracts use either competitive
or other than competitive proposals and discussions to
award the contract. Additionally, FIP resources can be
acquired under the small purchase program when the
items cost less than the small purchase threshold of FAR
Part 13.
• Existing Contracts - Various contracts for providing FIP
resources to EPA components may be in place at any
given time. These may include program or mission-based
contracts, or agencywide (often OIRM managed) contracts
for hardware, software, services, etc. These contracts
usually provide economies of scale and help to ensure
compliance with agency and Govemmentwide standards.
When feasible, their use to satisfy new requirements will
help avoid unnecessary duplication of effort by client,
OIRM, and OAM staff.
• Lease - FIP resources can be leased via new or existing
contracts.
• Reuse - FIP resources considered excess to EPA
organizations or other agencies must be considered for
use prior to acquiring new FIP resources. Reuse includes
obtaining FIP items through the GSA Excess FIP
Equipment Program or purchasing used FIP items on the
open market at lower cost than new items.
'• Conversion - Conversion of FIP resources involves
changing from current FIP resources to new FIP resources
FIP Resource Acquisition Guide 2-15
-------
Chapter 2 FIP Resources Acquisition Environment Methods
NOTES either by adding to or upgrading existing FIP hardware and
software to prolong its useful life or completely swapping
current FIP resources for new, technically different,
hardware and software. Conversion usually involves at
least some procurement of resources, either through an
existing contract or a new contract.
• GSA Federal Supply Schedules - The GSA Federal Supply
Schedule is a mandatory source for widely used items for
which supplies have been solicited by GSA to obtain
favorable pricing for, and ready access by, all Government
agencies.
• GSA Nonmandatory Schedule Contracts for FIP
Resources - GSA provides various service and assistance
programs and contracts to help agencies meet their IRM
requirements. (These are not part of the Federal Supply
Service [FSS] schedule program covered in FAR Subpart
8.4.)
• Telecommunications Support Contracts - GSA, through its
Telecommunications Support Contracts (TSC) can provide
Federal agencies with access to expertise in
voice/data/video systems analysis, systems integration,
network engineering and design, RA, specification
development, system testing and acceptance, strategic
and tactical planning, and other related services.
• Purchase of Telecommunications Services Contracts -
GSA has established nonmandatory Purchase of
Telecommunications Services (POTS) contracts to provide
telecommunications supplies and services, including
purchase, installation, maintenance, repair, de-installation,
and relocation of both contractor-provided and
Government-owned telephone equipment, throughout the
country. The POTS contracts are available for use by all
Federal agencies.
• GSA Mandatorv-for-Use Programs - GSA operates several
mandatory programs which are required to be used by
Federal agencies unless the agency has a specific
FIP Resource Acquisition Guide 2-16
-------
Chapter 2 FIP Resources Acquisition Environment Trail Boss
NOTES exception to the program. Examples of GSA Mandatory-
for-Use Programs include:
0 FTS-2000
, 0 Consolidated Local Telecommunications Service
0 GSA POTS Contracts (mandatory for certain locations)
1 0 National Security and Emergency Preparedness
1 \
0 FMSS Mandatory MAS Contracts Program
i
• GSA Mandatorv-for-Consideration Programs - GSA
operates and manages services and assistance programs
which must be used if EPA requirements can be met by
the programs and using them is the most
advantageous alternative to the Government.
Examples of the Mandatory-for-Consideration Programs
include:
0 Federal Software Exchange Program
HI
0 Telecommunications Assistance Programs and
Services
These sources are detailed in the GSA Acquisition of Federal
Information Processing Resources Overview Guide.
Trail Boss Program
GSA has established the "Trail Boss" program as an
alternative means of managing major FIP acquisitions. This
program allows an agency to appoint a single acquisition
manager, the Trail Boss, with the authority and responsibility to
manage an integrated programmatic, technical, and contracting
support team. By definition, a Trail Boss must have prior
experience with major FIP resource acquisitions. Use of the
Trail Boss program can facilitate major FIP acquisitions. (See
: FIRMR 201 -20.305 and FIRMR Bulletin C-7.)
FIP Resource Acquisition Guide 2-17
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Chapter 2 FIP Resources Acquisition Environment
OAM/OIRM
Coordinate
NOTES Organizational Support
Acquisition of FIP resources within EPA is not the sole
responsibility of the client PO but requires the coordinated
efforts of several organizational components. When initiating an
acquisition, client POs must understand the intricate working
relationships among EPA organizations. These organizations
are delegated specific responsibilities in the acquisition process
but, in addition, are readily available to assist the PO in initiating
and managing the acquisition project. POs should take full
advantage of the expertise and services provided. Early and
continual coordination with these organizations will facilitate the
acquisition and ensure that EPA acquires IT and services in a
cost-effective and appropriate manner.
Office of Acquisition Management
OAM is responsible for implementing contracts to acquire the
full range of goods and services for EPA. OAM COs provide
assistance in acquiring FIP resources, particularly when the
acquisition involves establishing a new contract.
Early coordination with OAM is vital to a smooth acquisition.
OAM coordinates all agency contracts and can, therefore,
provide information on existing or interagency contracts which
can be used to acquire FIP resources. The CO prepares,
publicizes, and issues solicitations for FIP resources with
coordination and assistance from the client organization. The
client PO works closely with the CO in developing formal
acquisition documents and procedures including the acquisition
plan, market surveys, solicitation and evaluation documents,
and evaluating proposals.
Office of Information Resources
Management
OIRM is responsible for the management of the FIP resource
acquisition process within EPA to ensure compliance with
Federal and agency regulations, polices, and procedures.
OIRM manages EPA's DPA process for acquiring FIP resources
in coordination with GSA. Also, OIRM manages EPA's IRM
FIP Resource Acquisition Guide 2-18
-------
Chapter 2 FIP Resources Acquisition Environment OCSS/OSDBU
! NOTES ] strategic planning process. The IRM Strategic Plan establishes
i : a framework for agency acquisitions of FIP resources.
1 OIRM is a valuable source of information for the client PO.
i Coordination with OIRM should begin as soon as the client
i determines a requirement for FIP resources exists. OIRM can
i provide vital information on existing OIRM-managed agencywide
i . contracts and other Governmentwide FIP resource vehicles.
; OIRM also works with POs to comprehensively analyze the
' organization's FIP resource requirements and consult on the
development of the IRM portions of an acquisition. For FIP
: resource acquisitions that require a DPA from GSA, the Director,
| OIRM has been delegated responsibility for approving APRs
! prior to submitting them to GSA.
I ; Oversight and Compliance Support Staff
. i
; i OCSS implements OIRM's FIP resource acquisition oversight
! > authorities. OCSS reviews FIP resource acquisitions to ensure
] , compliance with applicable agency and Federal regulations and
: : policies.
OCSS also provides training and technical consultation to
agency acquisition and IRM personnel. OCSS Desk Officers
are assigned to specific Headquarters and Regional programs
' and administrative organizations to provide individualized
; ; support to the client POs. OCSS also serves as EPA's liaison to
i GSA and reviews and processes APRs for transmittal to GSA.
: \ Office of Small and Disadvantaged Business
• Utilization
t
; The Office of Small and Disadvantaged Business Utilization
| (OSDBU) coordinates EPA opportunities for small and
i disadvantaged businesses in cooperation with, and under
! guidance from, the Small Business Administration, the
i Department of Commerce, and GSA. This office assists EPA
organizations in participating in Federal preferential
; procurement programs for small and disadvantaged businesses
that meet the applicable regulatory criteria. In some instances,
FIP Resource Acquisition Guide 2-19
-------
Chapter 2 FIP Resources Acquisition Environment SIRMO
NOTES tne leacl time for accluirin9 FIP resources can be reduced when
taking advantage of these programs.
SIRMOs for Programs, Regions, and
Administrative Organizations
SIRMOs for Regions and Headquarters program and
administrative organizations (e.g., Office of Inspector General
[OIG] and Office of General Council [OGC]) are responsible for
effectively planning for and managing FIP resources within their
respective organizations. Each organization's SIRMO is
responsible for directing officewide information resources
planning and budgeting. SIRMOs also are responsible for
ensuring that the organization's information systems and
technology acquisitions are in accordance with published
regulations, policies, standards, directives, and guidance.
SIRMOs project long-range FIP requirements in the context of
both organizational and agency environments and ensure the
requirements originate from and are supported by the
strategic and multiyear IRM plans and budgets.
Early coordination with SIRMOs is necessary to prevent
duplication of effort and resources within the organization as
well as for approval of required acquisition documentation.
Client POs work closely with SIRMOs in identifying FIP resource
needs and alternative sources of acquisition. SIRMOs are
authorized to approve FIP resource acquisitions within specific
thresholds stipulated in EPA Delegation 1-10. Acquisitions
exceeding these thresholds require OIRM approval in addition to
the SIRMO's. Finally, any acquisition (FIP or non-FIP) that
exceeds $1 million, requires approval by the organization's
Senior Resource Official (SRO).
FIP Resource Acquisition Guide 2-20
-------
Chapter 3 Acquisition Process Overview
Overview
3. ACQUISITION PROCESS OVERVIEW
NOTES
The acquisition process is a series of life cycle activities
designed to provide an agency with efficient and effective
technology and services to support information needs. Well
developed acquisitions effectively integrate all mandated Federal
and EPA requirements to ensure a smooth acquisition. This
chapter presents a high-level overview of a "typical" Federal
acquisition process, familiarizing the reader with the purpose and
scope of each phase and establishing the logical sequence of the
process.
The acquisition process as presented in this guide is divided
into five life cycle phases: Initial Planning, Presolicitation,
Solicitation, Source Selection, and Contract Administration.
Exhibit 3-1 illustrates the five phases and the main objectives of
each phase.
The FIRMR places special emphasis on the early phases of
the acquisition life cycle. The special planning and analytical
requirements it establishes are intended to ensure that all
contract SOWs flow from well-structured statements of functional
requirements. Planning and analytical requirements are the focus
of the first two life cycle phases of the process. These planning
and analytical requirements represent a departure from the
customary practice of developing the SOW as the first step of
the acquisition process.
This overview focuses on the "contract" approach to acquiring
FIP resources and, therefore, includes the type of activities
necessary to obtain FIP resources by contract. Acquisition by
other than contracting will not necessarily require all activities in
this chapter, however, the initial planning activities should be
applied to any type of acquisition to ensure that EPA needs are
satisfied in the most technologically appropriate and cost effective
manner.
FIP Resource Acquisition Guide 3-1
-------
Chapter 3 Acquisition Process Overview
Life Cycle
PHASE 1: Initial Planning
• Identify future needs
• Budget for FIP resources
• Examine feasible solutions
• Begin acquisition planning
PHASE 2: Presolicitation
• Analyze and develop functional requirements,
alternatives
• Select best alternative
• Obtain EPA management & GSA approvals
for acquisition by contract (if applicable)
PHASE 3: Solicitation
• Prepare PRP
• Develop evaluation criteria
• Distribute solicitation
PHASE 4: Source Selection
• Evaluate technical & cost/price proposals
• Award contract
PHASES: Contract Administration
• Monitor contract progress, cost, quality
• Assess contract performance
ACQUISITION LIFE CYCLE
Exhibit 3-1
FIP Resource Acquisition Guide 3-2
-------
Chapter 3 Acquisition Process Overview
Planning
Cwnliiute
NOTES Phase 1 - Initial Planning Phase
The decision to initiate an acquisition for FIP resources
should be made in the context of a deliberate and strategic
planning process. Within EPA, FIP resource planning begins
^ with the agency's IRM Strategic Plan. This plan establishes the
' basis for each organization's Multiyear IRM Implementation
Plan, which defines the objectives, projects, and initiatives
necessary to implement the strategies in the IRM Strategic Plan.
To facilitate the process of planning and analysis, an
organization's management should focus on its information
requirements. Key functional areas for consideration when
determining information requirements include information
collection, processing, transmission, dissemination, storage,
retrieval, and disposal. Other areas of consideration include
agency records management requirements, current system
limitations, sensitivity of information, the impact of new or
planned agency initiatives, and the current "state-of-the-art" in
IT. In all cases, information and FIP resource requirements
must clearly be driven by the agency's mission and goals.
Identifying the need for FIP resources in advance of when
they will be needed is critical. The lead time for determining
budget requirements for FIP resources normally is
approximately two years. Most agencies "call for budget
estimates" approximately 12 months before the fiscal year for
which the budget is being formulated. At this point, the agency
must have identified the general FIP resource requirements that
will be met in the fiscal year being budgeted for, feasible
alternatives for meeting those requirements, and the
approximate costs.
If this process results in a decision to acquire FIP resources
by contract, then the client and the CO should begin formulating
the acquisition plan. In planning and budgeting for FIP
resources, it should be kept in mind that the typical lead time for
acquiring FIP resources by contract is between 18 and 24
months. When specific programs such as small and
disadvantaged business set-asides or GSA's Trail Boss program
are used, the lead time for acquiring FIP resources can be
reduced.
FIP Resource Acquisition Guide 3-3
-------
Chapter 3 Acquisition Process Overview
Presolicitation
NOTES
I Approval |
Phase 2 - Presolicitation Phase
The Presolicitation Phase encompasses the analyses,
documentation, and approvals required to advance the
acquisition project to the point of preparing the solicitation
document. Client organizations are responsible for several
initial presolicitation activities including: determining FIP
resource needs, defining requirements, evaluating alternatives,
selecting the alternative most advantageous to the Government,
preparing an IP, and (if required) preparing a conversion study
and an APR to GSA. Client organizations may request technical
assistance from the appropriate IRM organization in performing
these tasks.
The majority of FIRMR-mandated analyses and tasks
required for a FIP resource acquisition are to be completed
during this phase. As soon as the client determines that an
acquisition will be by contract, the organization should contact
OAM. CO involvement in the early phases of the acquisition can
help avoid unnecessary work and problems later in the process.
At a minimum, the client should work with the CO in performing
the following tasks:
• Developing the individual acquisition plan (this process
begins in the Initial Planning Phase)
• Conducting a market survey
• Preparing Justification for Other than Full and Open
Competition (JOFOC) (if necessary)
After the most technological/cost effective alternative has
been determined and approval to continue has been granted by
the appropriate EPA organization and, if applicable, GSA, the
client PO can progress to preparing the actual solicitation
package in Phase 3.
FIP Resource Acquisition Guide 3-4
-------
Chapter 3r Acquisition Process Overview Solicitation/Selection/Contract
NOTES Phase 3 - Solicitation Phase
This phase focuses on preparing and distributing the
solicitation to potential bidders. The client prepares the SOW
including specifications for Section C of the solicitation, works
with the CO to define evaluation criteria, and provides input to
other sections of the solicitation related to user requirements.
Large, complex acquisitions require establishing formal
procedures to evaluate an offerer's technical and cost
proposals. These procedures should be established prior to
releasing the solicitation. The CO prepares, publicizes, and
issues the solicitation and may be assisted by client or IRM
personnel.
Phase 4 - Source Selection Phase
Activities in this phase center on preparing for, receiving, and
evaluating the proposals. The Technical Evaluation Panel
(TEP) can consist of representatives from the client
organization, the client's IRM organization, and other
organizations such as OIRM, as appropriate. The TEP
evaluates the technical proposals based on the evaluation
criteria and procedures established in Phase 3. The CO is
responsible for cost/price evaluation and the source selection
decision based on technical and cost evaluation results. The
CO awards the contract.
Phase 5 - Contract Administration
Phase
The last phase focuses on monitoring the contract. Once the
contract has been awarded, the CO normally delegates the
responsibility for certain functions such as monitoring the
contractor's progress, tracking costs, and inspecting and
accepting deliverables to the client PO. EPA often further
delegates many of these tasks to Delivery Order Project Officers
(DOPOs) and Work Assignment Managers (WAMs).
Post-implementation reviews and ongoing assessments of
performance can provide input to an agency's PIP resources
FIP Resource Acquisition Guide 3-5
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Chapter 3 Acquisition Process Overview Contract Administration
NOTES i Panning process. This information should be provided to
! planners so that system enhancements and replacements can
be accomplished as needed.
Contract management reviews are required by the FIRMR
and provide feedback regarding the adequacy and management
of contract acquisitions of FIP resources. Costs are tracked by
FIP resource category to ensure delegated procurement
thresholds are not exceeded and to determine improvements in
the management process.
FIP Resource Acquisition Guide 3-6
-------
Chapter 4 Acquisition Process and Procedures
Process
4. ACQUISITION PROCESS AND PROCEDURES
NOTES
The acquisition process presented in this guide is a series of
five cyclic phases which guides the reader through acquiring
resources and reporting on acquisition progress. Each phase is
divided into steps which include specific activities, procedures,
and requirements. This chapter details the specific phases and
steps comprising the process. The narrative for each step
includes a statement of the purpose or objective of the step and a
description of the process and results. The action taken or
result(s) of each step is annotated as:
• Documentation Requirement
• Processing Requirement
• Recordkeeping Requirement
• Approval Requirement
Exhibit 4-1 illustrates the acquisition process15 phases and 19
steps.
The process detailed in this chapter focuses on acquiring FIP
resources by contract. Other methods of acquiring FIP resources
(e.g., in-house, sharing, excess, GSA-mandated for use) vary
from the process presented in this guide. However, the
acquisition process through Step 7 Begin Implementation
Planning is basically the same for most acquisitions regardless of
the acquisition method and source and should be followed until
subsequent procedures are issued. The process description and
the specific procedures it contains, should be viewed as a QA
checklist.
The term "client" is used throughout the document to indicate
any EPA individual, usually a PO, that initiates, submits for
approval, or manages a FIP resources acquisition. Unless stated
otherwise (e.g., client management or organization), the guide
uses the terms "client," "client PO," and "PO" synonymously.
FIP Resource Acquisition Guide 4-1
-------
PHASE 1
Initial
Planning
s
I
STEPI
Identify FIP Resource
needs
STEP:
Rcconctk needs with
existing budgets, resources
and plans, update plans
as needed
STEP)
Document mission needs.
feasible solutions, and
FIRMR applicability
STEP 4
Obtun intenul cuenl of£in-
lulion approvals 10 proceed
STEPS
Begin acquisition planning
PHASE 2
Presolicitation
i
STEP6
Deteraiine mission-based
analyze ahemauvc soluuons
STEP?
Begin unplemenl
planning
STEPS:
forDPA
STEP 9
Pfcpvc APR
STEP 10
Obtain menial client
organuatiOD approvals of
APR package
STEP 11
Obtain ORM
•pptDvu of APR ptcufc
STEP 11
ObaiDOIRM.Diicctor.
approval of APR package
STEP 13
Obtain GSA approval of
APRpicfcige
PHASE 3
Solicitation
±
STEP 14
Prepare procurencni ftqueu
(PR) package
STEP 15
OIRM. OAM review
PRpKkage
STEP 16
tii> Soucitation
PHASE 4
Source
Selection
STEP IT
Evaluate proposals ml award
PHASES
Contract
Administration
a
TJ
STEP IB
Tuck HP mourn
casts and re pan status
1.
STEP 19
Rcpon OPA stilus to CSA
ACQUISITION PHASES AND STEPS
Exhibit 4-1
-------
Chapter 4 Acquisition Process and Procedures Process
NOTES "Client organization" refers to the PC's organization within EPA,
or the organization on whose behalf the acquisition is being
conducted. "Client organization management" refers to the
appropriate organizational chain of command for review and
approval of required acquisition documents. Signature authority
for client organization management approvals is at the Division
Director (or equivalent) level or above.
f
The roles of POs, managers, SIRMOs, SROs, COs, and other
staff and oversight officials are referenced throughout the
process. The PO, in particular, has a critical role in ensuring the
success of any FIP resource acquisition. As described in this
chapter, the PO is responsible for developing a number of key
acquisition documents and for steering an acquisition through
the various stages of the approval process. Exhibit 4-2 lists the
actions taken during the various phases and the responsible
party, concurring or coordinating organization, and/or the
approving authority.
EPA personnel involved in FIP resources procurement
should review the following regulatory and guidance documents:
FAR Part 6, Acquisition Planning; FAR Part 34, Major Systems
Acquisitions; FIRMR Part 201-1 through 201-24 and 201-39;
EPAAR 1510, Specifications, Standards, and Other Purchase
Descriptions; EPAAR 1534, Major Systems Acquisitions; and
appropriate parts of the EPA Property Manual. Appendix D lists
the specific references by each step in the process.
This chapter is based on FAR, FIRMR, and EPA policy and
guidance. It is intended not only to ensure that EPA's
acquisitions comply with these directives, but also to foster
quality in planning for, acquiring, and managing FIP resources.
Review and approval procedures prescribed in this guide are not
intended to replace or negate any existing internal review or
acquisition approval procedures.
FIP Resource Acquisition Guide 4-3
-------
Chapter 4 Acquisition Process and Procedures
Activities
Responsible Party
Concur/ Coordinate
Approve
PHASE 1 • INITIAL PLANNING PHASE
STEP 1: Identify Information ind FTP resource needs
• Identify future FIP resource requirements
Client Org
SIKMO
STEP 2: Reconcile needs with existing budgets, resources, and plans;
update plans as needed
- Reconcile costs with plans, budget
- Identify potential sources of FIP resources
Client PO
SIRMO. Client IRM
Client PO
SIRMO. OAM.
OIRM. Other
Organization SIRMOs
STEP 3: Document mission needs, feasible solutions, and FIRMR applicability
- Prepare Mission Needs Statement (MNS)
• Prepare Feasibility Statement
• Prepare FIRMR Applicability Statement
Client PO
Cient PO
Client PO
STEP 4: Obtain internal client organization approvals to proceed
- Consolidate MNS. Feasibility, and FIRMR Applicability Statements
- Prepare cover memo and submit analysis package to client management
- Review, approve, return
- Submit package to SIRMO (SRO if required)
- Review, approve, return
- Maintain package and approvals for future review
Client PO
Client PO
Client Mgmt
dent PO
SIRMO. SRO
Client PO
STEP 5: Begin acquisition planning
- Coordinate Acquisition Plan
- Develop and update portion's of Acquisition Plan
OAM. CO
Client PO. SIRMO
OAM.OSPBU
PHASE 2 • PRESOLICITATION PHASE
STEP 6: Determine mission-based functional requirements and analyze alternative
solutions
- Develop Requirements Analysis
- Develop Alternatives Analysis
Client PO
Client PO
iTEP 7: Begin implementation planning
• Develop IP
Support services
Other client-acquired resources
National Computer Center acquired resources
- Maintain IP and modification's for review
Client PO
Client PO
OIRM
Client PO
TEP 8: Determine requirement for DPA
- Estimate cost of resource for entire life of contract
- Prepare a DPA Applicabilily/Non-Applicability Statement and cover memo
- Review and concur/non-concur on DPA applicability
- Maintain cost estimate, applicability statement, and concurrences for review
Client PO
Client PO
Client Mgmt. SIRMO.
SRO
Client PO
STEPS 9 THROUGH 13 ARE TO COMPLETED IF A DPA IS REQUIRED.
OTHERWISE, PROCEED TO STEP 14.
TEP 9: Prepare APR
- Prepare APR package
Client PO
FIP Resource Acquisition Guide 4-4
-------
Chapter 4 Acquisition Process and Procedures
Activities
Responsible Puty Concur/ Coordinate
Approve
STEP 10: Obtain internal dient organization approvals of APR package
- Submit package to management for Approval *.
- Review and approve APR package
- Prepare cover memo for submission to OIRM
- Maintain APR package and approvals for future review
Client PO
diem Mgmt,
SIRMO.SRO
Client PO
QientPO
STEP 11: Obtain OIRM approval of APR package
• Submit APR package to OIRM
"Review and opprovc APR package
Client PO
OIRM
STEP 12: Obtain OIRM Director approval of APR package
• Prepare cover letter to GSA
- Submit package to director. OIRM
• Review and approve APR package
-Submit package to GSA
- Maintain APR package for future review
OIRM
OIRM
Director. OIRM
Director. OIRM
Client PO
STEP 13: Obtain GSA approval of APR Package
- Approve APR package
- Correspond with GSA on package
- Forward approved DPA to client or assist with appeal
GSA
OIRM
OIRM
PHASE 3- SOLICITATION PHASE
STEP 14: Prepare PRP
• Develop PRP
- Develop security plan
• Prepare memo teoucsting approval
- Submit PRP for approval (approval is dependent on S amount)
Client PO
OAM.OSDBU
Client PO
Client PO
Client PO
Client Mgmt.
SIRMO.SRO
STEP 15: OIRM and OAM Review PRP
,/ -Submit PRP to OIRM
- Review and approve PRP
-Submit PRP to OAM
-Review and approve PRP
- Initiate solicitation preparation
diem PO
OIRM
Client PO
OIRM.OSDBU.
Client PO
OAM
OAM
• Maintain PRP and concurences for future review
Client PO
STEP 16: Issue Solicitation
- Adveitise acouisition as reouiied
• Issue solicitation to requesting vendors, as appropriate
OAM
OAM
PHASE 4 - SOURCE SELECTION PHASE
TEP17: Evaluate proposals and award contract
- Develop technical instructions and evaluation criteria
- Evaluate technical proposals
* AwQfd contfQct ,
OAM, Client PO
TEP
OAM
PHASE 5 - CONTRACT ADMINISTRATION
TEP 18: Track FIP resource costs and report status
- Track contract costs
Client PO. CO
TEP 19: Report DPA status to GSA
- Provide GSA required DPA status and contract expenditures information
OIRM
FIP Resource Acquisition Guide 4-5
-------
Chapter 4 Acquisition Process and Procedures
Planning
NOTES Phase 1 - Initial Planning Phase
The Initial Planning Phase is designed to guide the client
through identifying the FIP resource needs to initiating
acquisition planning. This phase fulfills Federal and EPA
acquisition planning requirements. The planning activities and
documentation developed during this phase lay the groundwork
for a successful FIP resources acquisition. Exhibit 4-3 illustrates
the steps in Phase 1 - Initial Planning Phase.
PHASE 1
Initial
Planning
^ 1
PHASE 2
Presolicitadon
PHASE 3
Solicitation
STEP 1: Identify information and FIP resource needs
i
STEP 2: Reconcile needs with existing budgets, resources and plans;
update plans as needed
STEP 3: Document mission needs, feasible solutions, and FIRMR
applicability
STEP 4: Obtain internal client organization approvals to proceed
STEP 5: Begin acquisition planning
PHASE 1: INITIAL PLANNING
Exhibit 4-3
FIP Resource Acquisition Guide 4-6
-------
Chapter 4 Acquisition Process and Procedures
Stepl
NOTES
Step 1 - Identify Information and FIP
Resource Needs
Step 1 implements the initial planning process. This step
generally describes the process that EPA organizations should
follow to evaluate how FIP resources will be used to support the
organization's mission and goals.
All major operating organizations (Assistant
Administratorships) within EPA, are required to identify their
long-range and immediate FIP resource needs in order to
effectively plan for and manage these resources. This planning
process involves the organization's SIRMO and SRO and should
reflect the information management needs of the entire
organization, down to the branch and section level. To
adequately identify FIP resource needs, it is first necessary to
have a thorough understanding of the information requirements
of the organization. These needs must be viewed within the
context of both the organization and agency's information
management environment.
Process and Results
Client organizations are responsible for identifying FIP
resource needs. The first step for a client organization to take is
to determine its information needs, in functional terms. Basic
questions to answer, among others, include:
• What information must be collected, processed,
distributed, and stored; and where it is located?
• How much of it is there?
• What are its format, processing, communications, storage,
reproduction, and accessibility requirements?
• What are its reliability requirements?
• What are its security requirements?
FIP Resource Acquisition Guide 4-7
-------
Chapter 4 Acquisition Process and Procedures
Stepl
NOTES
Coordinate
Information need identification and analyses can be
facilitated through direct observations; surveys; internal program
management studies, reports, audits, and reviews; existing
contract reviews; etc. Once the information needs are
understood, the client can identify and verify the extent to which
FIP resources (e.g., computers, software, data entry services)
are necessary to meet these needs.
Federal and EPA policies prescribe that FIP resource
requirements be mission-based. For example, to implement a
new Clean Air Act requirement, EPA regulations could require
emission sources to submit annual emission monitoring reports.
These reports could contain valuable monitoring data for the
National Air Program. The Program Office's need to effectively
manage this data represents an "information need or
requirement". As a result, the Program Office (i.e., client) needs
to consult with management and the SIRMO to determine the
extent to which new FIP resources will be needed.
Neither the IRM strategic nor multiyear planning processes
will identify all agency requirements for FIP resources and new
requirements will continue to emerge as needs change.
Regardless of how or when an information requirement is
identified, the client organization is responsible for verifying the
information requirement and consulting with the SIRMO to
determine whether the needs are addressed by the
organization's Multiyear IRM Implementation Plan, whether the
need conforms to the plan, or whether the plan needs to be
modified to reflect the new need.
The agency's IRM Strategic Plan and an organization's
Multiyear IRM Implementation Plan are valuable references in
evaluating organizational FIP resource needs. If the review of
these planning documents indicate the need to acquire FIP
resources, the acquisition must adhere to the remaining steps of
the Initial Planning Phase.
FIP Resource Acquisition Guide 4-8
-------
Chapter 4 Acquisition Process and Procedures Step 2
NOTES Step 2 - Reconcile Needs with Existing
! Budgets, Resources, and Plans;
1 Update Plans as Needed
! Step 2 begins the process of verifying that the client's
' perceived needs conform to existing IRM plans and the
organization's current and projected budgets. It also provides
the client the opportunity to identify possible existing sources for
meeting the organization's FIP resource needs. Again, an
organization's SIRMO is an important point-of-contact in this
assessment process.
When a need for FIP resources is first identified, the client
organization must ensure that the acquisition is conducted in
accordance with the agency's and the client organization's IRM
planning and budgeting processes. To receive the necessary
approvals, the FIP resource need must be supported by the
technical and budgetary aspects of the organization's IRM plan
and budget.
New and unforeseen needs, or new advances in ADP
technology, may require an organization to modify its needs
analysis. The new information should be factored into existing
plans and budgets. This reconciliation of new realities with
; existing plans and budgets is an iterative process and should be
: considered at crucial points in the planning and acquisition life
cycles. For large FIP procurements, this step is particularly
. critical when a new contract will be established to acquire the
FIP, particularly because of the difficulty of modifying the
contract afterward.
Reconciling perceived needs with existing plans and budgets
early in the process ensures:
• Consistency between an organization's acquisition
initiative and its IRM plans and budget projections.
• The need for in-house full-time equivalent (FTE) resources
is adequately considered when it is determined to be the
most cost effective means of fulfilling the need, or most
advantageous to the Government.
FIP Resource Acquisition Guide 4-9
-------
Chapter 4 Acquisition Process and Procedures
Step 2
NOTES
Opportunities to separate and/or consolidate FIP resource
requirements or share existing FIP resources are
considered.
• New requirements are incorporated within the planning
and budgeting process.
These actions strengthen the budget request and negotiation
process by linking specific acquisition plans to larger
organizational goals. They also help identify opportunities to
acquire FIP resources through existing contracts or other
means, thus eliminating the need to undertake the lengthy (up to
two years) process of acquiring FIP resources through a new
contract.
Process and Results
The client reconciles FIP resource needs with existing plans,
budgets, and FIP resource availability. The client, generally the
PO, or mid-level management, should consult with the SIRMO
and review the agency's and organization's IRM plans. These
IRM plans should describe missions, goals, and objectives, and
provide resource estimates for attaining those goals.
Acquisitions can take considerable time and extend across
fiscal years; therefore, budgeting and planning for FIP resources
acquisitions should begin as soon as the need for FIP resources
is identified. For example, as new legislation is passed by
Congress or a decision to issue new regulations is made by the
agency, organizations should consider the implications of these
changes to their long-term information needs and the effects on
existing data and FIP resources (e.g., hardware, software,
systems).
Early in the process, the client should identify alternative
sources for meeting the organization's FIP resource needs.
This "preliminary survey" is a high-level poll of any options that
may be available for satisfying the needs. This survey will save
time and avoid potential duplication of effort and resources.
Additionally, the FIRMR requires organizations to investigate
and consider alternative resources prior to initiating a new
FIP Resource Acquisition Guide 4-10
-------
Chapter 4 Acquisition Process and Procedures
Step 2
NOTES
CooHinatc
contract. Alternative method/sources of acquiring resources are
detailed in Chapter 2.
The client organization's SIRMO must verify whether or not
existing FIP resources can be used to meet the need, therefore,
the client PO should consult with the SIRMO at both the
beginning and the end of this high-level review process.
Additionally, the client PO should coordinate with the following:
• OAM to determine if there are any other existing or
proposed procurements of FIP resources with the
potential to satisfy the organizational needs. In addition,
the client should investigate the possibility of obtaining the
needed resources from another agency through an IAG.
Guidance on the IAG process is contained in EPA's
Interagency Agreement Policy and Procedures
Compendium.
• SIRMOs in other organizations and POs of existing
contracts that may be used by the client organization.
• OIRM to identify centrally managed contracts and
contracts managed by other Federal agencies, including
GSA's Federal Information Systems Support Program
(FISSP) (zone contracts) and DoD, where applicable, and
available for EPA use. Sources of information regarding
potentially usable contracts and other sources include the
various IRM-related periodicals, the Commerce
Business Daily (CBD), GSA's Electronic Bulletin Board
System (EBBS) and On-Line Schedule System (OSS)
(see Appendix B), and informal "networking" among IRM
and acquisition professionals.
The process of identifying FIP resource needs, reviewing
potential alternative sources, documenting critical information,
and coordinating with appropriate parties requires an early
commitment of staff resources by the organization. The level of
effort is often underestimated, leading to delays later in the
acquisition process.
FIP Resource Acquisition Guide 4-11
-------
Chapter 4 Acquisition Process and Procedures Step 3
NOTES The potential sources/methods identified in this step are
analyzed in Step 3 to determine which sources are feasible for
meeting the client's FIP resource needs. However, in the event
an available contract is identified as a potential source, the PO
should answer the following questions:
• Does the potential source meet all needs and quantities?
• Is the timeframe of availability sufficient to satisfy needs?
• What are the overhead or management costs versus costs
of establishing and managing an in-house contract?
• What is the lead-time, if any, for accessing any of the
viable existing contract vehicles?
After the client PO has identified possible methods of
satisfying the needs, the estimated costs must be reconciled
with existing budgets to ensure their adequacy. Resource
needs and budgets will have to be reassessed and revised
following the detailed analysis of the alternatives in the process
(Step 6).
Step 3 - Document Mission Needs, Feasible
Solutions, and FIRMR Applicability
This step begins the analytical activities of the initial planning
phase and requires the client PO to complete three specific
analyses:
• Mission Needs - The mission needs analysis involves
analyzing and documenting the information needs and any
FIP resource needs to be met by the acquisition to support
the organization's and agency's missions.
• Feasible Solutions - This analysis identifies potentially
feasible solutions for meeting the mission needs.
• FIRMR Applicability - This analysis determines and
documents whether or not the FIRMR is, or may be,
applicable to the acquisition.
FIP Resource Acquisition Guide 4-12
-------
Chapter 4 Acquisition Process and Procedures
Step 3
NOTES
Process and Results
Document
Requirement
The client PO must prepare a Mission Needs and Feasibility
Statement that is commensurate with the size and complexity of
the need. It must contain sufficient information for the SIRMO
and client organization management to:
• Understand the information management problem that is
being addressed
• Assess the need for FIP resources
• Evaluate the adequacy and feasibility of the potential
solutions
• Determine whether to proceed with the acquisition
In the mission needs analysis portion of the document, the
client PO must describe the organization's information needs
and how the proposed acquisition of FIP resources will help
support those needs. The analysis should be clear and concise
and justify the need for acquiring the resources. Client
management will need to review the analysis to determine how
and whether to proceed with the acquisition.
The feasibility analysis section identifies and describes all
potential solutions at a high level and determines which
solutions are feasible. This analysis is the basis for the detailed
AAs conducted in Step 6.
These two analyses are documented in the Mission Needs
and Feasibility Statement. This statement does not need to
contain detailed descriptions or costs; however, the cost
estimates included should be based upon a realistic assessment
of needs and budget projections. This document is the
foundation for acquisition planning, RAs, and AAs required by
FIRMR Part 201-20 and completed in Step 6 for all FIP resource
acquisitions, regardless of type or size. Therefore, the need for
the Mission Needs and Feasibility Statement to be accurate and
comprehensive cannot be overemphasized.
FIP Resource Acquisition Guide 4-13
-------
Chapter 4 Acquisition Process and Procedures
Step3
NOTES
Document
Rcquironent
Following completion of the Mission Needs and Feasibility
Statement, the client PO determines whether the FIRMR applies
to the proposed acquisition or not and prepares the FIRMR
Applicability Statement which describes in detail the rationale for
that determination. Additional FIRMR requirements may apply
when an acquisition containing a FIP resources component is
accomplished by contracting. Whether FIP resources are
actually to be supplied to EPA, or are required to be used by the
contractor in providing the contract deliverable, the acquisition
must be conducted in accordance with the applicable policies
and procedures in FIRMR Part 201-39, as well as FIRMR Part
201-20.
Federal policy states that FIP resource needs should be
aggregated on an organizational or functional basis when
feasible, and that requirements for FIP resources not be
segmented to avoid regulatory limits (especially dollar limits).
An organization's SIRMO can assist in identifying opportunities
to consolidate FIP requirements across an organization (e.g.,
across Program Offices or Divisions.)
When FIP resource requirements are identified in conjunction
with non-FIP requirements, the client organization should
consider whether to separate the FIP resource component into a
separate acquisition. A stand-alone contract should be
considered whenever the FIP resource component is separable
and of sufficient size. Often this is not a simple matter. One
important test of separability when acquiring FIP support
services is whether programmatic technical knowledge is
essential to performing the support service tasks. Guidelines
regarding separability are contained in FIRMR Subpart 201-
20.305. The potential cost of creating multiple contracts should
also be considered.
Mission Needs Statement
The Mission Needs Statement (MNS) provides a high-level
description of the organization's information needs, their affect
on the ability to accomplish the organization's mission, and how
the proposed FIP resources acquisition will meet these needs.
The document should describe how the proposed FIP resources
acquisition will support attainment of the organization's
FIP Resource Acquisition Guide 4-14
-------
Chapter 4 Acquisition Process and Procedures Step 3
NOTES programmatic and IT goals. It should also reflect agency IRM
goals (e.g., data standardization and integration), where
appropriate.
The MNS should briefly describe the functions, program
areas, and user personnel (or organizations) affected by the
information needs and associated FIP resource needs. For
example, if the Resources Conservation and Recovery Act
(RCRA) Division in each region needs information to track and
monitor corrective actions at hazardous waste facilities, the
need should be stated in the document. In addition to the
current need, briefly describe the current information and FIP
resources environment and its support systems (automated and
non-automated), equipment, services used, staffing, limitations,
confidential business information (CBI) and other security
requirements, and any other special considerations.
The document should identify the problems with the current
environment that hinder accomplishing the organization's
mission and/or meeting information needs. The objective of the
acquisition should be to retain the positive aspects of the current
environment, while correcting deficiencies. Specifically, if a new
contract is intended to replace an existing contract, the analysis
should include a description of the FIP resources delivered
through the current contract. The problem and current
environment must be sufficiently documented to support the
identification of feasible solutions. The mission needs
documentation provides a foundation for the RA performed in
Step 6.
Feasibility Statement
The Feasibility Statement describes and evaluates, at a high
level, potential solutions for satisfying the FIP resource needs.
It is a screening tool intended to eliminate potential solutions
that are not viable and focus on those that appear to be feasible.
The potential solutions identified in this statement form the basis
for the more detailed alternatives analysis performed in Step 6.
The feasibility analysis includes a high-level estimate of the
technical and economic characteristics and risks associated with
each solution. Each organization's goals and information needs
for meeting those goals will be different.
FIP Resource Acquisition Guide 4-15
-------
Chapter 4 Acquisition Process and Procedures Step 3
NOTES The ana|ysis in the Feasibility Statement should build upon
the information collected and potential solutions identified in
Step 2, stating any assumptions and constraints that apply.
State the methodology and criteria used to determine potential
solutions. Solutions selected must be capable of meeting
mission needs.
Provide a brief description and a high-level cost estimate for
each feasible solution. The descriptions must explain how each
solution could meet the organization's requirements. It should
also describe any effects the option may have on other existing
or proposed acquisitions and systems. The analysis should
briefly address issues such as timing, scope, availability,
staffing, and management considerations.
A rationale for eliminating any potential solutions that are not
considered feasible must be included in the document. Include
a proposed schedule for subsequent activities (e.g., RA, AA, IP),
and state when the resource must be placed in service.
This analysis will determine feasible solutions to satisfying
the FIP resource needs. These solutions will then be thoroughly
analyzed in the AA (Step 6) to determine the most
advantageous alternative for the Government.
After completing the Feasibility Statement, the client PO
may be able to determine whether a new contract will be
necessary to satisfy the requirement, or whether an existing
contract, sharing of resources, an IAG, or other solution
would be most appropriate. If more than one feasible solution
is identified, however, further analysis will be necessary before a
final decision can be made.
FIRMR Applicability Statement
The FIRMR governs the acquisition, management, and use of
FIP resources. In this step, the client PO must determine
whether the acquisition provisions of the FIRMR apply to the
proposed FIP resources acquisition. When the FIRMR
acquisition provisions apply, the FIRMR establishes a series of
procedural and documentation requirements intended to ensure
successful FIP resource acquisitions. (Note: When the phrase
FIP Resource Acquisition Guide 4-16
-------
Chapter 4 Acquisition Process and Procedures • Step 3
NOTES "FIRMR applicability" is used in this chapter, it refers strictly to
the acquisition provisions of the FIRMR and not the entire set of
requirements-established by this regulation).
At a minimum, these FIRMR requirements include completion
of an RA, AA, IP, and, if applicable, a Conversion Study and an
APR. The decision concerning FIRMR applicability should be
re-evaluated if the scope, substance, or size of the acquisition
changes significantly.
As stated in FIRMR Parts 201-1 and 201-39, "the FIRMR
, , applies to the acquisition, management, and use of FIP
resources by Federal agencies." In other words, FIRMR policies
! and procedures must be followed whenever FIP equipment,
' software, services, support services, FlP-related supplies, and
systems are acquired by a Federal agency, whether by
contracting or other method, for its own use or for the use of a
non-Federal user designated by a Federal agency.
Additionally, the FIRMR applies to any solicitation or contract
that requires the performance of a service or the furnishing of a
product that is performed or produced making significant use of
FIP resources that are not incidental to the performance of the
, contract.
Significant use means:
• The service or product could not reasonably be produced
or performed without the use of FIP resources; and
• The dollar value of FIP resources used by the contractor
to perform the service or produce the product will likely
exceed $500,000 or 20 percent of the estimated cost of
the contract, whichever is lower.
FIP resources are incidental when:
• None of the principal tasks of the contract depend directly
' on the use of FIP resources; or
• Nothing in the contract has the effect of substantially
restricting the contractor's discretion in the acquisition and
FIP Resource Acquisition Guide 4-17
-------
Chapter 4 Acquisition Process and Procedures
Steps
NOTES
management of FIP resources (whether or not the use of
FIP resources is specifically stated in the contract).
Exhibit 4-4 is a flowchart containing six questions designed to
assist procurement personnel in determining whether the FIRMR
applies to the FIP resources in the solicitation based on the
criteria described above.
Question 1 asks: "Does the solicitation or contract require
the delivery of FIP resources for use by a Federal agency or by
any non-Federal agency users designated by the agency?"
Whenever the answer to this question is "Yes," the FIRMR
applies, regardless of the dollar value of the FIP resource(s)
required. The key consideration in Question 1 is "delivery" of
FIP resources. If the solicitation or contract does not require
delivery of FIP resources, then the FIRMR may still apply if the
FIP resources of the solicitation meet the criteria of "significant
use of non-incidental FIP resources."
Questions 2, 3, and 4 of the flowchart focus on identifying
"incidental" versus "non-incidental" uses of FIP resources. The
FIRMR does not apply to FIP resources that are "incidental" to
contract performance. If, however, the FIP resources are "not
incidental" to contract performance, then Questions 5 and 6
must be considered to determine whether there is "significant
use" of the FIP resources in question.
Even with the guidance provided by the FIRMR flowchart,
determining FIRMR applicability and the associated
requirements is not an exact science. The dollar value of a
requirement is not always a major criterion nor is the fact that a
computer is used to perform a task determinative of whether a
task is defined as a FIP resource. Often the way in which an
SOW or requirement is structured or worded can make a crucial
difference. For example, if a computer is used to do tasks that
were once performed manually (e.g., perform statistical analysis
of an array of data), use of the computer is considered use of a
"tool", and performance of that task is most likely not a FIP
resource requirement.
FIP Resource Acquisition Guide 4-18
-------
Chapter 4 Acquisition Process and Procedures
FIRMR Applicability
Question 1: Does the soliatation or contract require
the delivery of FIP resources for use by a Federal
agency or by any non-Federal agency users
designated by the agency?
NO|
T
Question 2: Does a principal (ask of the solicitation or
contract depend directly on the use of FIP resources?
FIP resources are incidental
to contract performance
FIRMR is
not
applicable
to contract
action
V
Question 3: Do the requirements of the solicitation or
contract have the effect of substantially restricting the
contractor's discretion in the acquisition and
management of FIP resources?
A
Yesl
W y "
XX
FIRMR Is
applicable
to contract
action
FIP resources am not
incidental to contract
performance
Question 4: Does the soliatation or contract explicitly
require the use by the contractor of FIP resources?
T)
Yes
Yes
Question 5: Could the service or product required by
the soliatation or contract reasonably be performed or
produced without the use of RP resources?
There Is no
significant use of
FIP resources
i
Themis
significant use ol
FIP resources
No
Question 6: Would the dollar value of FIP resources
expended by the contractor to perform the service or
furnish the product be expected to exceed the tower
of $500,000 or 20 percent of the estimated cost of
the contract?
Yes
FIRMR APPLICABILITY DECISION FLOW CHART
FOR ACQUISITIONS BY CONTRACT
Exhibit 4-4
FIP Resource Acquisition Guide 4-19
-------
Chapter 4 Acquisition Process and Procedures Step 3
NOTES 'f' however, the SOW describes "how" the work of a task or
contract is to be performed (e.g., using a computer), as opposed
to focusing on the substantive requirement (e.g., statistical
analysis), the FIRMR criteria for non-incidental use may be
triggered. This situation is best avoided by writing an SOW,
task, or contract requirement in "functional" terms.
A functional requirement describes "what" work is required,
not "how" the work is to be performed. It describes the service,
product, or deliverable required by the Government and does
not dictate how the contractor should satisfy the requirement.
Writing contract requirements in functional terms is a
recommended contracting practice.
FIRMR Subpart 201-1.002 and FIRMR Bulletin A-1 provide
more detail on determining FIRMR applicability. Appendix E
also provides additional guidance.
Once FIRMR applicability has been determined, the client PO
should consider the following:
• When FIP and other resources (non-FIP goods or
services) are acquired through a contract action, the
FIRMR only applies to the FIP resources.
• When the FIRMR requires inclusion of provisions and
clauses controlling the contractor's acquisition of FIP
resources, the FIRMR does not apply to the FIP
resources acquired by the contractor that are incidental to
contract performance.
Embedded Equipment is FIP equipment that is an integral
part of the product, where the principal function of the product is
not the "automatic acquisition, storage, manipulation,
management, movement, control, display, switching,
interchange, transmission, or reception of data or information".
A microprocessor contained in scientific or chemical analysis
equipment used for analyzing air and water is an example of
embedded equipment.
The FIRMR does not apply to acquiring, managing, and using
products containing embedded equipment when:
FIP Resource Acquisition Guide 4-20
-------
Chapter 4 Acquisition Process and Procedures
Step 3/4
NOTES
CoonJinate
Document
Rcquu
• The embedded FIP equipment would need to be
substantially modified to be used other than as an integral
part of the product, or
• The dollar value of the embedded FIP equipment is less
than $500,000 or less than 20 percent of the value of the
product, whichever amount is lower
Step 4 - Obtain Internal Client Organization
Approvals to Proceed
r"
This step obtains all necessary client organization approvals
of the Mission Needs and Feasibility and FIRMR Applicability
Statements and authorization to proceed with the acquisition.
The client PO will need approval from Division-level
management, the SIRMO, and, under certain conditions, the
SRO.
Within EPA, the SIRMO for the originating office is
responsible for direction of officewide information resources
planning and budgeting. The SIRMO also ensures that the
office's information systems and IT acquisitions comply with
Federal/EPA regulations and policies and are consistent with
the agency's IRM plans. In addition, any procurement (i.e., FIP
or non-FIP) over $1 million dollars must be approved by the
SRO in accordance with EPA Order 1130.2. Consequently, it is
recommended that the client PO coordinate with the SRO to
determine whether their approval is required here or later in the
process.
The client PO must take the initiative here, and throughout
the acquisition process, to make certain that all required
documentation is complete and well supported and that all
required reviews and approvals are accomplished in a timely
manner.
Process and Results
The client PO consolidates the Mission Needs and Feasibility
and FIRMR Applicability Statements into one package to
facilitate the review and approval process. The PO prepares a
FIP Resource Acquisition Guide 4-21
-------
Chapter 4 Acquisition Process and Procedures
Step 4
NOTES
Approval
RMJUI rcracnt
cover memo requesting appropriate client management review
and approval and SIRMO concurrence (e.g., signature lines).
The memo summarizes or references the results of the
analyses, particularly with respect to the FIRMR applicability
determination. This step applies to all types of FIP resource
acquisitions (e.g., new contracts, lAGs, and delivery orders/work
assignments if required by the client's internal office policy).
The client PO submits the package to internal management
for review and approval. Client management reviews the
package and approves it or returns it to the client PO for
revision, clarification, etc.
After receiving internal management approval, the PO
forwards the package to the SIRMO for review and concurrence.
The SIRMO's review should verify the following:
• The FIP resources in question are appropriate for
supporting the information needs and are in conformance
with organizational and EPA IRM planning and policies (as
discussed in Step 2).
• No other similar efforts are underway that may affect this
effort.
>
• No need exists to provide excess capacity to other
organizations and no opportunities exist to meet
requirements from existing FIP resources.
• Needs are adequately described, in functional terms, and
in a manner that does not unnecessarily eliminate viable
alternatives from consideration.
• The identified alternatives are as complete as possible and
can satisfy needs.
• Estimated costs are realistic and conform to IRM and
programmatic short and long-term plans and budgets.
• The PO's FIRMR applicability determination is valid.
FIP Resource Acquisition Guide 4-22
-------
Chapter 4 Acquisition Process and Procedures
Step 4/5
NOTES
Approval
Requirement
Retorf keeping
Requirement
Upon review of the package, the SIRMO may offer
recommendations or advice, return it for revisions, or concur
with the package and its findings.
If, after internal management and SIRMO reviews, it is
determined that the FIRMR does not apply to the acquisition, the
acquisition does not require OIRM approval. The PO should
follow applicable standard Federal and EPA procurement
procedures for non-FIRMR applicable acquisitions.
Even if it is determined that the FIRMR does not apply to the
acquisition, the PO should recognize that the initial
determination of FIRMR applicability is based on the high-level
mission needs and ^feasibility analysis. In some instances, FIP
requirements will emerge as the SOW is developed. As a result,
the question of FIRMR applicability may have to be considered
more than once for an acquisition.
The entire Mission Needs, Feasibility and FIRMR
Applicability Statement package, including approvals, must be
maintained in the client's permanent acquisition file and must be
available for OIRM or other official review. This applies to all
other decision and approval documents in the acquisition life
cycle, as well.
When the PO sends the procurement package to OAM for
approval and action, the CO may conclude that the FIRMR
applicability is unclear and request OIRM review and approval of
the procurement package. This review may delay contract
processing, particularly if the initial analysis is determined to be
incomplete or inaccurate. Thus, client management should
monitor the subsequent acquisition documents against the initial
mission needs/feasibility "baseline," and any revisions to the
baseline document. The client must ensure that all necessary
actions are taken to meet FIP acquisition requirements.
Step 5 - Begin Acquisition Planning
This step addresses the preliminary planning activities
required to accomplish an acquisition. If the Feasibility
Statement determined that acquisition by contract is the only
FIP Resource Acquisition Guide 4-23
-------
Chapter 4 Acquisition Process and Procedures Step 5
NOTES feasible alternative, an individual acquisition plan as prescribed
by the FAR and EPA policy is initiated.
The FAR states that acquisition planning "should begin as
soon as the agency need is identified, preferably well in
advance of the fiscal year in which contract award is necessary.
In developing the plan, the planner shall form a team consisting
of all those who will be responsible for significant aspects of the
acquisition, such as contracting, fiscal, legal, and technical
personnel". "Acquisition planning" and the "acquisition plan"
mandated by the FAR are clearly oriented toward acquisitions
by contract and address the contracting, rather than technical
and operational aspects of the acquisition.
FIP resources implementation planning, required by the
FIRMR, applies to all FIP resource acquisitions, whether by
contract or not. Implementation planning normally follows
development of the AA and addresses the technical,
operational, and logistical aspects of placing the selected
alternative into operation. FIP resource implementation
planning is discussed in Step 7.
Acquisition planning is a dynamic process that begins early
by identifying needs and available funds, and may extend
beyond contract award to address ongoing contract
administration. The result is an individual acquisition plan that
identifies the activities and tasks involved, the roles and
responsibilities of program personnel and the acquisition team,
schedules, costs, risks, and other contract-related
considerations. The plan is a living document that will evolve as
the key elements of the acquisition (e.g., SOW) progress.
Process and Results
Chapter 1 of the EPA Contracts Management Manual
discusses planning responsibilities. It sets a threshold of $5
million ($25 million for Superfund) above which a written
individual acquisition plan for an individual procurement is
required. Chapter 1 assigns the leadership role for the
acquisition plan to the 0AM CO for the acquisition. Acquisitions
requiring a DPA are required to have an acquisition plan even if
less than the $5 million threshold.
FIP Resource Acquisition Guide 4-24
-------
Chapter 4 Acquisition Process and Procedures
StepS
NOTES
Docunwm
Requirement
Coordinate
The client PO and SIRMO develop initial portions of the
individual acquisition plan, and continue developing or updating
the plan as the acquisition progresses. The PO obtains OAM
and OSDBU assistance and guidance as appropriate.
Advanced planning is necessary to ensure that contract
management resources will be available for the acquisition, to
begin developing tentative schedules for completing analyses,
to develop source selection documents, and to form the
acquisition team. During the reconciliation process described in
Step 2, the client should have reconciled whether or not an
existing contract or other source is available, identified
long-range acquisition milestones, and identified budgetary
constraints that may affect the acquisition process.
For major procurement of FIP resources, 01RM recommends
that the client PO attend or have already attended the GSA Trail
Boss training. The Trail Boss training is designed to strengthen
the acquisition skills of agency staff and to enable an
organization to acquire FIP resources in a more expeditious
manner.
Development of the acquisition plan for a Trail Boss
acquisition still must be carefully planned, coordinated with
OIRM, and approved in advance by OAM. The team should
consist of representatives from the client's IRM organization or
staff, SIRMO, OIRM, the Program Office, OAM, and other
organizations if appropriate. If possible, the team should
participate in preparing parts of the acquisition plan. For
example, the team should be involved in determining the source
selection criteria for award.
The acquisition plan should be reviewed and updated
throughout the acquisition life cycle. Item five of the APR
(prepared in Step 9) requires information on the "contracting
approach". Therefore, the client PO must at least perform
preliminary acquisition planning prior to completing the APR.
The level of effort expended should correspond to the
estimated cost and complexity of the resources to be acquired.
If the PO expects the FIP resources component of the
acquisition to exceed EPA's regulatory or specific agency
FIP Resource Acquisition Guide 4-25
-------
Chapter 4 Acquisition Process and Procedures Step 5
NOTES delegated procurement authority, then additional time should be
allowed for obtaining a DPA from GSA.
When developing a plan for acquiring resources by contract,
the PO should keep in mind that solicitations should promote full
and open competition to the greatest extent possible; thus
allowing all responsible offerers the opportunity to compete.
Avoid unnecessary restrictions in the solicitation such as
educational level, experience, location, or performance
requirements that may restrict competition while not providing
for improved performance. Through the competitive process,
EPA obtains the best possible price, and may discover an
innovative solution to the problem. *
Limiting competition can result in numerous problems. These
problems are usually encountered after valuable resources have
been expended. A thorough, well executed plan will help avoid:
• A potential for protest
• GSA disapproval based on unnecessary constraints on
competition
• OMB or Congressional intervention
• Acquiring resources that are not the most advantageous to
the Government
FIP Resource Acquisition Guide 4-26
-------
Chapter 4 Acquisition Process and Procedures Presolicitation/Step 6
NOTES Phase 2 - Presolicitation Phase
Phase 2 - Presolicitation Phase of the acquisition life cycle
builds on the planning and analyses accomplished during the
Initial Planning Phase. In this phase, the client identifies
specific functional requirements and alternatives and, if
required, satisfies Federal requirements to obtain an APR. In
this phase, RAs, AAs, and other documents required by Federal
regulations are produced, building on the Mission Needs,
Feasibility, and FIRMR Applicability Statements developed in
the previous phase. Exhibit 4-5 illustrates the steps in the
Presolicitation Phase.
All FIRMR-applicable acquisitions go through basically the
same procedures, up through development of the IP in Step 7..
The analyses and documentation produced during this phase
provide the basic information from which the solicitation
documents will be developed in the next phase. If a DPA is not
required, the client PO can dispense with Steps 9 through
13 and proceed to Step 14.
Step 6 - Determine Mission-Based Functional
Requirements and Analyze
Alternative Solutions
• This step fulfills the FIRMR requirements to identify functional
requirements; analyze feasible alternative solutions; and select
the alternative most beneficial to the Government. Client
organizations undertaking an acquisition of FIP resources,
either by contract, in-house sources, or other means, must
perform and document an RA and an AA. The RA and AA build
and expand upon the Mission Needs and Feasibility Statement
developed in Step 3.
The RA describes information needs identified by an
• organization as necessary to meet its mission, identifies the FIP
resources needed to meet those needs, and serves as the basis
for the AA. It also identifies, outlines, and establishes the basis
for the FIP resources described in the SOW (i.e., Description/
Specifications Section) in the solicitation document.
FIP Resource Acquisition Guide 4-27
-------
Chapter 4 Acquisition Process and Procedures
Presolicitation
PHASE 1
Initial
Planning
PHASE 2
Presolicitation
i
r
— P
PHASE 3
Solicitation
•
• •
STEP 6: Determine mission-based functional requirements and
analyze alternative solutions
STEP 7: Begin implementation planning
STEP 8: Determine requirement for DPA
STEP 9: Prepare APR
i.
STEP 10: Obtain internal client organization approvals of APR
package
STEP 11: Obtain OIRM approval of APR package
STEP 12: Obtain OIRM Director approval of APR package
STEP 13: Obtain GSA approval of APR package
PHASE 2: PRESOLICITATION
Exhibit 4-5
FIP Resource Acquisition Guide 4-28
-------
Chapter 4 Acquisition Process and Procedures
Steps
NOTES
Document
The AA identifies and evaluates^the various alternatives for
meeting the requirements identified in the RA, comparing the
technical and economic (i.e., cost/benefits) merits of each
feasible alternative. The "bottom line" objective of the AA is to
select, from all available feasible alternatives, the one that fulfills
the need satisfactorily and is the most cost effective to the
Government.
Although a formal RA and AA are not required for
acquisitions to which the FIRMR does not apply, the same type
of analytical process should be used in selecting the most
advantageous alternative and writing the contract/solicitation
SOW.
Process and Results
The client PO develops the RA and AA. For both of these
analyses, a rule of reason should guide decisions regarding the
documents' length and detail. The rule of reason, as it applies
to the size and complexity requirement, can be interpreted in
several ways. First, if an acquisition consists entirely or mostly
of FIP resources, it is presumed to be an important IRM
acquisition and one requiring comprehensive planning and
analysis. r.
Another acquisition type that requires careful planning and
thorough analysis is a mission support contract that contains a
high cost FIP resource component. In these cases, the level of
detail, documentation, and justification will be higher than other
acquisitions where the FIP resources are less mission-critical.
By contrast, mission-based contracts with a small amount of FIP
embedded in them will require less extensive analysis and
documentation. However, both of these analyses must clearly
describe the FIP resource required and how they will address
the program's information management needs. If an RA can not
meet this criteria, it can not be approved. Similarly, the AA
should articulate why the selected alternative represents the
best solution for the program and the agency.
FIP Resource Acquisition Guide 4-29
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES Requirements Analysis
The RA analyzes and documents the FIP resource
requirements, in functional terms, and provides the basis upon
which various alternative solutions for meeting the requirements
can be analyzed and evaluated. The RA is based on the high-
level needs identified in the MNS prepared in Step 3. First, the
information needs of major program functions (e.g., water
quality monitoring) must be identified and described.
Information needs should be linked to agency and program
missions. Next, the FIP functional requirements must be
described concretely and objectively in the context and terms of
the activities they will support (e.g., processing storage and
maintenance of water quality data for ecosystem
characterization activities).
The FIRMR Subpart 201-20.1 lists a number of factors that
the RA must address as one formulates and documents the FIP
requirements for an acquisition. They are:
• Information Needs - Determine information needs by
considering the need to collect and/or provide information
to and obtain information from the public, regulated
entities, other organizations within EPA, and other
Governmental agencies, and by determining available
sources of information. Also consider information format,
media, quantity, integrity, security, and timeliness
requirements.
• System Life - When developing, enhancing, or
modernizing an ADP system, determine the system life for
costing purposes when the AA is performed. The span of
the system's projected life is from installation
(implementation) to disposal/completion, or replacement,
and must be established in the RA. If the acquiring
organization can predict reuse of the FIP resource by
another component within the agency after it no longer
meets the acquiring organization's needs, include the
reuse period in the system life. (When describing
requirements for services, system life can be translated to
the time over which the services will be needed. When
FIP Resource Acquisition Guide 4-30
-------
Chapter 4 Acquisition Process and Procedures
Step 6
NOTES
contracting for services, it may be synonymous with
contract life, including^!! periods and options.)
• Description of Requirements - Provide a discussion of why
the FIP resources are necessary to meet mission-related
needs. Describe information requirements in functional
and performance terms. Explain how the required
resources will support organizational goals and objectives.
Identify opportunities for increased economy and
efficiency, new or changed program requirements, or
deficiencies in existing capabilities. Describe
requirements in a manner to allow for full and open
competition (unless otherwise fully justified). Document
quantitative or qualitative requirements that must be met.
• Compatibility-Limited Requirements - This type of
requirement must be included in the JOFOC, which is part
of the PRP discussed in Step 14 and in Appendix G. It is a
required document for the PRP.
• Specific Make and Model Justifications - This type of
requirement also must be included in the JOFOC, which is
part of the PRP discussed in Step 14 and in Appendix G.
It is a required document for the PRP.
• Accessibility Requirements - Consider accessibility
requirements for people with disabilities or impairments.
FIRMR Bulletins C-8 and C-10 provide guidance on the
topics of disabilities and impairments.
• Security Requirements - Identify security requirements
necessary to protect classified and sensitive information.
(This includes special attention to protection and handling
of Federal Insecticide, Fungicide, and Rodenticide Act
[FIFRA], Toxic Substances Control Act [TSCA]), and any
other CBI.) List the potential threats and hazards and
describe the measures necessary to provide protection.
Identify necessary physical and environmental security
safeguards.
• Space and Environmental Requirements - Identify space
and environmental requirements as they apply to
FIP Resource Acquisition Guide 4-31
-------
Chapter 4 Acquisition Process and Procedures
StepS
NOTES
personnel, supplies, equipment, etc. For example,
hardware acquisitions must consider facility size, floor
plans, cooling and heating requirements, and utility layout
and availability.
• Workload and Related Requirements - Consider such
factors as projected processing, storage, data entry,
communications, and support services workload
requirements over the system life (or life of the services to
be acquired), and how best to address workload un-
certainties. Also, consider expandability requirements,
performance evaluation of currently installed FIP
resources, and contingency requirements for FIP
resources whose loss or failure would prevent EPA from
performing its mission.
• Records Management Requirements - Include records
management factors in the RA. Consider essential
records, records retention, disposition requirements, and
integrating electronic records with other agency records.
Also consider existing or planned intra- or interagency
interoperability requirements.
For each functional requirement that FIP resources will
support, the RA should address the applicability and issues
relating each item to the acquisition. Items that are not
applicable should be stated as such with a brief explanation, as
necessary.
As previously noted, the rule of reason should ensure the
effort expended on the RA is commensurate with the size and
complexity of the acquisition project. This rule, however, does
not exempt EPA organizations from sufficiently analyzing and
documenting requirements. Even though the guidance
presented in this guide will be most useful for significant
system acquisitions, the information can be successfully
applied to more modest information management tasks
(e.g., data entry, local area network [LAN] administration,
and limited computer programming requirements) found in
smaller FIP contracts.
FIP Resource Acquisition Guide 4-32
-------
Chapter 4 Acquisition Process and Procedures Step 6
' NOTES Requirements included in the RA must be quantified to the
extent practical as well as described in functional terms.
Quantification may be in terms of processing volumes, actions
completed, staff-hours expended, or whatever form of
; measurement is appropriate to the work being supported or
performed.
The traditional, most popular analytical methods for gathering
i information for an RA are included as follows:
! • Workflow Analysis - A workflow analysis is a "top down" •
analysis of the flow of work that the FIP resources will
accomplish or support. Workflow analysis requires
defining system inputs, system outputs, and the processes
that translate the inputs to the outputs. The "system"
involved may be either manual or automated, or a
combination of the two. Workflow analysis may require
diagramming the flow of work.
• User Survey - A user survey projects requirements from
the end-users upward. This method often is well suited to
analyzing requirements for support services. The users
are surveyed regarding their current and projected needs.
The needs are aggregated to find total requirements for
the organization requiring the FIP resources. User
; surveys can be supplemented by focus group discussions
and interviews with key users, personnel responsible for
programs that will use the FIP resources, and information
systems personnel. Surveys are well suited for collecting
requirements for distributed resources. Surveys are also
well suited for collecting requirements for a central
resource that is required by distributed user customers.
• Current Situation Review - A current situation review
begins by reviewing the agency's current FIP resource
requirements and determining a reasonable model of what
resources are required to meet the current workload. Like
the user survey method, this method often is well suited to
1 analyzing requirements for support services. Situation
review may involve staffing, equipment, PCs, or other
quantitative measures of resources. The review is
; conducted by personnel performing the RA in conjunction
FIP Resource Acquisition Guide 4-33
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES with managers of the current program who are familiar with
the functions to be performed. Once an ideal set of
current requirements is determined, growth projections are
made for each of the future periods of the system life.
Current situation review is often well suited to analyzing
staffing support services requirements.
There are other, less traditional, analytical methods for
gathering information that have evolved from developments in
business area analysis and data modeling. These less
traditional methods should be considered when a significant FIP
acquisition is envisioned. These methods are documented in
GSA's A Guide to Alternate Requirements Analysis
Methodologies (September 1990) and include:
• Reverse Engineering - Reverse engineering is the process
of analyzing an existing system to define current system
requirements; thus, providing the basis for users to
determine requirements for a new or modernized system.
This method is particularly useful when an organization
invested considerable resources in the current system and
has limited funds to upgrade the system.
• Delphi Method - The Delphi Method is a process of
developing a series of questionnaires, sending them to a
panel of "experts" for responses, then tabulating and
analyzing the results to generate system requirements.
The process is iterative with all responses analyzed before
the next specialized questionnaire is written. The Delphi
Method is applicable when experts are widely separated
geographically and cannot be easily brought together for
meetings.
• Interactive Design - Interactive design is based on
facilitated workshop participation by representatives of the
user community and the technical organization. This
method fosters a team approach and may be most
effective for systems that are used by operational business
(non-computer) professionals.
FIP Resource Acquisition Guide 4-34
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES Analysis of Alternatives
The purpose of the AA is twofold: first, to analyze and
evaluate various alternative technical solutions for satisfying the
functional requirements and secondly, to help determine which
acquisition source is the most advantageous for the
Government. Ideally, the RA and AA process should end with a
recommendation for the alternative that is technically and
operationally capable of satisfying the requirement and that
demonstrates the best comparison of benefits to costs.
The AA builds and expands on the Feasibility Statement
prepared in Step 3, as well as the detailed functional
requirements in the RA. The AA should address the solutions
identified as potentially workable in the Feasibility Statement,
and any new solutions that may become evident following the
RA process. Particular attention should be given to the use of
in-house resources; interagency resource support; contracting,
which includes purchasing or lease-to-purchase of equipment;
using existing contracts; sharing resources; re-use of existing
resources; and GSA's mandatory-for-use programs (e.g., FTS-
2000) and mandatory-for-consideration programs (e.g., the
Federal Software Exchange Program and the Excess FIP
Equipment Program).
Prior to conducting a full-scale AA, the PO should consider
whether the results of the RA, or other new information, make
; any of the potential solutions identified in the Feasibility
Statement no longer viable. For example, using the user survey
technique, an organization may discover its information
processing requirements are growing more rapidly than
' anticipated, and enough so that the option of using an existing
contract is no longer feasible.
Because acquisition requirements can change and because
new acquisition issues may arise in the RA process, the PO
should screen the remaining alternatives using the following
criteria prior to conducting the AA:
• Can the potential solution satisfy the functional
requirements as described in the RA?
FIP Resource Acquisition Guide 4-35
-------
Chapter 4 Acquisition Process and Procedures
Step 6
NOTES
Coordinate
• Have administrative and implementation cost issues arisen
since the Feasibility Statement (e.g., significant changes
in overhead rates)?
• Have organizational issues arisen since the Feasibility
Statement that make a solution impractical (e.g., loss of
staff or elimination of a function)?
• Do all solutions continue to be viable based on capacity or
availability considerations (e.g., lifespan or ceiling of an
existing contract)?
• Have compatibility-limited specifications or sole-source
requirements been identified in the RA process? Do these
requirements need to be confirmed through a market
survey, or do they potentially affect the scope of viable
alternatives?
If the answers to these questions eliminate an alternative that
was once considered feasible, then the rationale for eliminating
the option should be documented in the AA, and further analysis
of the option is not required.
The FIRMR requires agencies to perform a market survey to
determine available technology or contracts that can meet
requirements. The market survey is a cornerstone of the AA
and should be performed whether the client specifies
requirements functionally or identifies specific service
characteristics or methods. POs should consult OAM for
guidance in performing a market survey.
The market survey will provide the organization with
knowledge of what FIP resources are available from private
industry and other parts of the Government, including verifying
the technical feasibility of satisfying requirements; determining
the amount of available competition; collecting cost information
for estimates and comparative cost analyses; and identifying
industry norms and business practices for acquiring or using FIP
resources.
The level of effort and description in the AA should reflect the
size and complexity of the requirement to be satisfied. Again,
FIP Resource Acquisition Guide 4-36
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES the rule of reason should be applied in developing the AA. For
example, if only one viable alternative can be identified, then the
analysis need only compare the costs, benefits, and risks of that
alternative to the current situation (e.g., existing contract), at a
reasonable level of detail. However, when the analysis
identifies more than one viable alternative, the AA must fully
consider four factors in reviewing each alternative:
• Cost of each alternative
• Benefits of each alternative
• Risks associated with each alternative
• Sensitivity of each alternative to changing assumptions
(e.g., staffing, organization, mission)
Following the narrative description of all of the alternatives
that were considered, the AA must contain an analysis of the
costs and benefits of each alternative.
COSTS - The cost analysis must include, for each alternative,
an estimate of the various costs associated with that alternative
and a total for the entire acquisition. This information needs to
be broken-out by FIP resource type. For acquisitions of FIP
support services, the cost analysis should indicate the types of
support services being acquired and the approximate percent of
the total FIP represented by each type. The following
categories of FIP support services should be used in presenting
this information:
• Studies, Consulting, and Outside Training
• New Systems Development
• Systems Enhancements
• ADP User and Operational Support
If the anticipated cost of the FIP resource acquisition is
' $50,000 or less, cost analysis may be limited to demonstrating
that the benefits of the acquisition will outweigh the costs.
When the cost of the acquisition is above $50,000, the preparer
must calculate the total projected cost for each feasible
alternative, using the present value of money. "Present value" is
FIP Resource Acquisition Guide 4-37
-------
Chapter 4 Acquisition Process and Procedures
Step 6
NOTES
the concept of discounting dollar values for out year cost
projections to allow for the decreasing value of money over time.
OMB Circular 94 and FIPS PUB 64 contain guidance on present
value discounting. FIPS PUB 64 also contains detailed
guidance on performing cost/benefit analyses.
The total estimated cost for each alternative must include
both recurring and non-recurring costs over the life of the
system and any other costs identified with the alternative that
can be accrued either before or after the system life period.
System life costs refer to the cost of acquiring, operating,
maintaining, and disposing of or terminating the system,
equipment, services, or other resources being analyzed.
If applicable, a conversion study should be performed as
required by the FIRMR and the cost included in the AA. The
conversion study identifies transition planning issues, timing,
logistics, cut-overs, and cost issues that will likely be
encountered as the acquisition is implemented. Conversion
studies are required for all FIP resource acquisitions except for
initial acquisitions where no FIP resources exist; acquisitions of
FIP peripheral equipment only; or the exercise of a purchase
option under a leasing agreement. Costs are to include costs of
conversion and other expenses directly related to conversion.
FIRMR Bulletin C-14 should be consulted for more details.
Automated software conversion cost models are available
through GSA's Office of Technical Assistance (OTA).
Whenever in-house and contracting alternatives are identified
as viable alternatives, consult OMB Circular A-94 for information
pertaining to the in-house costs. If more than ten FTE are
involved, an OMB Circular A-76 commercial activities analysis is
required. Commercial activities are basically considered a
non-government function. For example, the purpose of EPA is
not to provide security, computer programming, janitorial, or
cafeteria services. These services may be required, but they
can be provided by commercial entities. OMB Circular A-76
prescribes criteria for selecting in-house performance over
performance by a commercial source based on cost
considerations. OMB Circular A-104, "Leases of Capital Assets"
should be consulted for consideration in leasing FIP equipment.
FIP Resource Acquisition Guide 4-38
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES BENEFITS - The benefits analysis examines both program
and IRM benefits. Program benefits are realized when FIP
resources are used to improve an organization's ability to
complete its mission. IRM benefits are improvements in the
management or service-providing characteristics of the
resources themselves (e.g., improved reliability, accuracy,
, usability, or administration).
Benefit descriptions must relate to EPA's mission, goals,
-functions, and operating environment and, wherever possible,
/be expressed in quantifiable terms. The rule of reason should
guide the level of analysis and the need to quantify benefits. At
a minimum, the program and service benefits must be listed and
described quantitatively. While quantifiable and non-
quantifiable benefits are important, quantifiable benefits are
objective and strengthen the justification for acquiring FIP
resources. If the FIP resources of a new contract are similar to
those of the existing contract it replaces, then the analysis can
be tailored to emphasize the differences.
Some benefits, especially those resulting from the acquisition
of professional and technical services, are difficult to quantify.
Generally, the more tangible the service or products, the easier
it is to identify and quantify benefits.
One approach to documenting non-quantifiable benefits is to
assign a value to benefits as a percentage of a related activity.
For example, if more effective facility management services
would make the FIP facility more available, thus allowing the
agency to process its forms more efficiently, the percentage
value of that increased efficiency could be used to estimate the
benefit of the service.
In some cases, the client may sufficiently establish the
expected benefits of acquiring a resource by examining the
threshold at which it becomes worthwhile. For example, if the
agency's programs spend $500 million and the resources to be
acquired would cost $50 million, the agency may consider the
alternative feasible if it believes that, in addition to any other
quantitative or qualitative benefits, the programs would be at
least 10 percent more efficient. The client would still need to
FIP Resource Acquisition Guide 4-39
-------
Chapter 4 Acquisition Process and Procedures Step 6
NOTES compare the value of this alternative to all others available to
determine its desirability.
RISKS - While documenting the alternatives, the organization
should consider the risks inherent in each alternative and the
general risks that the project faces regardless of the alternative
chosen. Some major risk factors for client organizations to
consider when evaluating technical alternatives are:
• Instability of Requirements - If the requirements are likely
to change (e.g., pending legislation will affect the EPA's
mission or increase or decrease the workload), the risk of
not accomplishing the mission or meeting goals increases.
• Project Scope - An increase in the number of organizations
involved and the number of people involved increases the
; risk.
• Project Management Ability - Risk decreases when the
project manager fully controls resources and has the
authority to commit them as needed.
• Project Staffing Levels and Skills - If the mix of project staff
and skill does not match the project requirements, the risk
of failure increases.
• Availability of Funds - Inadequate funding can cause
project managers to make poor decisions for the sake of
economy. It is important to scale the effort to the funding
available.
• Number and Types of Programs the Resources Support -
The more diverse the programs, the less likely that the
resources can support all of them equally and the greater
the risk.
• Senior Management Support - Risk should decrease as
senior managers become more involved.
Any noteworthy risk issues should be documented in the AA.
FIP Resource Acquisition Guide 4-40
-------
Chapter 4 Acquisition Process and Procedures
Step 6/7
NOTES
Document
Requirement
SENSITIVITY - After analyzing the cost, benefits, and risks,
the PO tests the sensitivity of the analysis, overall and for each
alternative, to changes in assumptions and constraints. For
example: If an FTE constraint were removed, would an
acquisition be necessary? Assuming the organization can use
an existing contract, would the life of the contract meet the
organization's needs? Assuming out-sourcing is feasible, would
out-sourcing allow EPA to upgrade its existing processing
environment? Would an increase or decrease in a given cost
factor affect the desirability of one alternative more than
another? The results of this exercise are documented in the
Sensitivity Analysis section of the AA.
Step 7 - Begin Implementation Planning
Implementation planning addresses the planning,
coordinating, and assignment of responsibilities for placing the
selected alternative into operation. This step implements this
planning process.
The FIRMR requires Federal agencies to develop an IP,
commensurate with the size and complexity of the selected
alternative. The IP addresses the technical, operational, and
logistical aspects of placing the alternative into operation. It
identifies the tasks that must be accomplished, schedules, and
responsibilities. The purpose of the IP is to ensure the agency
is well prepared to manage the FIP resources being acquired,
particularly in the early phase of contract implementation.
The client organization should designate an individual that
will be responsible for executing the IP. To the extent possible,
this individual should have primary management authority for all
the activities necessary to implement the selected alternative
(excluding contracting authority). This person can also be the
client PO or another person designated specifically for the role.
Process and Results
For FIP support services, the client organization develops the
IP. For hardware, software, telecommunications, and FIP
services that are acquired, operated, and managed centrally at
EPA's National Computer Center, the National Data Processing
FIP Resource Acquisition Guide 4-41
-------
Chapter 4 Acquisition Process and Procedures Step 7
NOTES Division will develop the IP. The client organization will develop
the IP for those items that they acquire, operate, and manage.
An IP focuses on implementing the selected alternative and
successfully placing the FIP resources into service. The IP
describes tasks, resources, key personnel, and schedules to
ensure successful implementation and includes agency and
contractor responsibilities. Tasks described in the plan include
meetings, briefings, installation, testing, training, maintenance,
and security planning. Resources include funds, hardware,
software, training, and facilities. Key personnel should include
individuals involved in the technical oversight of FIP activities or
services and relevant information on professional qualifications.
The schedule combines tasks and responsibilities with a
timeline for achieving the implementation. As with most
technical documents, any assumptions, constraints, or risks
should be identified and understood by those affected by the IP.
The IP is distinctly different from the acquisition plan. FAR
Part 7 focuses on contract/procurement activities,
prescribing that acquisition planning activities begin as soon as
the mission need has been established. The acquisition plan
addresses the activities and responsibilities that apply to
acquiring FIP resources by contract. FIRMR Part 201-20
requires an IP for all acquisitions of FIP resources, whether
by contract or not, and addresses the technical, operational,
and logistical aspects of implementing the alternative selected
as a result of the AA.
Conceivably, multiple IPs may be needed to support a single
acquisition if multiple FIP resources and/or multiple site
locations are involved. For example, one IP may address only
the hardware and facilities components; whereas another IP
may address the software, conversion, or telecommunications
components of the FIP resources. The "size and complexity" of
the acquisition will determine the extent of implementation
planning.
The IP should be started as soon after selection of the
optimum acquisition alternative as possible. At the latest, the IP
must be in place in time for submission with the APR or PRP, as
appropriate. The IP should be updated as the acquisition
FIP Resource Acquisition Guide 4-42
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Chapter 4 Acquisition Process and Procedures
Step 7/8
NOTES
Requirement
progresses and should continue to be updated during contract
start-up. Newly identified facts, constraints, and decisions that
develop along the way will cause some plans to be revised and
others to be addressed in more detail than they were in the
jinning.
The client PO will need to obtain internal management and
SIRMO concurrence/approval for the IP. The IP will also be
submitted to OIRM as a part of the PRP (Step 10). In addition,
the IP (and significant modifications) must be maintained in the
client's permanent acquisition file and be available for OIRM or
other official reviews.
Step 8 - Determine Requirement for DPA
This step determines whether a DPA from GSA is required for
the proposed procurement. The FIRMR does not require
organizations obtain a DPA from GSA for FlP-related supplies.
Therefore, references to APRs and DPAs in this guide are
referring to equipment, software, services, and support services
categories.
When GSA authorizes an agency to procure FIP resources
for itself, GSA is delegating procurement authority to the
agency, as authorized under existing regulations. GSA issues
the following three delegations:
• Specific Acquisition Delegations - Granted by GSA to
cover individual acquisitions exceeding the dollar
threshold of the regulatory delegation.
• Specific Agency Delegation - Granted after GSA performs
an Information Resources Procurement and Management
Review to agencies whose performance merits a higher
delegation threshold than the regulatory threshold.
• Regulatory Delegation - Establishes dollar thresholds
below which agencies may procure FIP resources without
obtaining GSA approval. Currently, the dollar threshold of
any individual FIP resource, including all optional
quantities and periods over the life of the contract (with the
exception of FlP-related supplies), is $2.5 million
FIP Resource Acquisition Guide 4-43
-------
Chapter 4 Acquisition Process and Procedures
StepS
NOTES
Document
Requirement
($250,000 for a specific make and model specification or
for requirements available from only one responsible
source).
These delegation categories are discussed in detail in
Chapter 2.
Specific acquisition delegations are required when a
procurement exceeds the $2.5 million or $250,000 cost
thresholds in any one of the four remaining FIP resource
category, over the life of the contract. This applies to new
contract acquisitions and modifications for additional
expenditures under existing contracts.
It is imperative that FIP resource requirements not be
separated into multiple procurements in an attempt to
circumvent the OPA thresholds stated in the FIRMR. Federal
acquisition regulations prohibit this activity and penalties can be
imposed on agencies and/or persons involved in this practice
(e.g., GSA can cancel not only the specific DPA but the agency
DPA as well).
A specific acquisition delegation authorizes the requesting
agency to procure FIP resources up to the new dollar threshold
established for that specific contract. This authorization is
accomplished by submitting an APR.
Process and Results
The client PO develops a cost estimate for the FIP resource
procurement over the entire life of the contract. The Feasibility
Study and AA performed during earlier steps establish the basis
for the client to estimate the costs of each FIP resource
category in the procurement, and an overall total. The cost data
will be used to determine DPA applicability and support the
development of the Independent Government Cost Estimate
(IGCE) for the PRP in Step 14.
In estimating the FIP resource costs, the client must ensure
that the full cost of each resource is included. For example,
when calculating FlP-related labor costs, fully loaded rates must
be used. For example, the total cost of a software developer
FIP Resource Acquisition Guide 4-44
-------
Chapter 4 Acquisition Process and Procedures
StepS
NOTES
Document
Requirement
with an estimated off-site hourly rate of $30 and an estimated
need of 10,000 hours over the life of the contract may appear to
be $300,000. However, when direct labor hours are subject to
overhead charges at 80 percent of labor and general/
administration charges at 20 percent of labor, the total cost of
this PIP resource could be as high as $600,000.
Cost estimating is not an exact science although there are
various methods which can be used to raise the level of
precision. One approach is to use historical information (e.g.,
cost data from similar existing contracts). However, these
estimates must reflect future needs and conditions. Estimates
for each FIP resource category should consider maximum case
scenarios and include some flexibility for changes that could
affect total FIP resource costs (e.g., bidder proposes additional
FIP resources).
GSA will grant a DPA only for the amount of FIP resources
identified in the APR, therefore, it is important to avoid
underestimating costs. When a DPA is required, it takes less
time and effort to request a higher procurement authority
initially, within reason, than to amend the APR. The cost
estimates must be realistic and based on well-developed
estimates of resource costs.
Using these cost estimates and applying FIRMR cost
thresholds and other criteria (see FIRMR Bulletin C-5), the PO
can determine whether a specific acquisition DPA is required.
The client PO documents the findings in a written statement of
DPA applicability (or non-applicability) for the proposed
procurement. This document should include enough
background and description of the requirement, cost information,
and the client's rationale, to enable a reviewer (e.g., SIRMO) to
verify the accuracy of the DPA applicability determination. The
estimated cost data should be summarized in tabular form,
including sufficient detail to support the client's decision.
The client PO prepares a cover memorandum requesting
written concurrence and submits the DPA Applicability
Statement to both appropriate client management and the
SIRMO. As discussed in Step 4, SRO concurrence may also be
required at this stage and the client PO is encouraged to
FIP Resource Acquisition Guide 4-45
-------
Chapter 4 Acquisition Process and Procedures
Step 8/9
NOTES
Requirement
Record keeping
Requirement
coordinate this issue as appropriate. (Note: To streamline the
internal approval process, client organizations may want to
consider delegating SRO approval authority to the SIRMO for
FIP acquisitions.)
Client management, SIRMO, and if appropriate, SRO concur
with the DPA Applicability Statement. After obtaining the
required concurrences, the client PO proceeds to the next
appropriate step in the process.
• If a DPA is required, the client PO must prepare an APR
(Step 9) for submission to GSA.
• If a DPA is not required, the client PO skips Steps 9
through 13 and proceeds with preparing the internal EPA
PRP(Step14).
Copies of the DPA Applicability Statement, written
concurrences, and all documentation supporting the FIP
resource cost estimates must be maintained as part of the
client's permanent acquisition file and be available for OIRM or
other official reviews when required.
Step 9 - Prepare APR
The APR, prepared in this step, is the formal vehicle for
requesting a DPA from GSA when a specific acquisition
delegation is required. Federal regulations require the agency's
Designated Senior Official (DSO), or an official designated by
the DSO, to submit an APR to GSA for any acquisition that
exceeds FIP resource procurement ceilings as prescribed in
FIRMR Subpart 201-20.305. EPA's DSO has designated the
Director, OIRM, responsibility for approving APRs and
requesting DPAs from GSA.
The APR provides concise information justifying the need for
the FIP resource procurement and an increase in the FIRMR
acquisition authority. The APR also establishes that adequate
and proper agency resources are available to support the
proposed FIP resources before and after award.
FIP Resource Acquisition Guide 4-46
-------
Chapter 4 Acquisition Process and Procedures
Step 9/10
NOTES
Process and Results
Document
Requirement
When a DPA is required, the client PO completes the APR
package in accordance with FIRMR Bulletin C-5, Instructions
For Preparing An Agency Procurement Request (APR),
addressing all applicable items (see Appendix F). The more
thoroughly a client has developed the RA, AA, IP, and
acquisition plan in previous steps, the easier it will be to prepare
the APR package.
EPA requires the RA, AA, and IP be submitted with the APR
package. In addition, OIRM, OAM, or GSA may require various
"regulatory compliance" documents listed in Item 7 of the APR
be submitted during their reviews. Approval from OIRM and
concurrence from OAM may depend on the client's ability to
provide the status or copies of that documentation, if requested.
The client PO must submit all APR documentation in hardcopy
and electronic media to OIRM/OCSS (i.e., 3.5" disk in
WordPerfect 5.1 or earlier version).
Step 10 - Obtain Internal Client Organization
Approvals of APR Package
Internal management and SIRMO approval of the APR
package are obtained in this step prior to submitting the APR
package to OIRM. Internal review and approval provides QA to
the acquisition process.
The client PO forwards the completed APR package,
including the RA, AA, IP, and a cover memo requesting review,
comment, and written approval (e.g., signature lines), to the
client organization management (including the SRO). The
client's SIRMO must concur with the APR package prior to
submission to OIRM. OIRM will not review the package and will
return the package if it is not signed by the SIRMO. (Note:
Special acquisition procedures for the Trail Boss program are
described in FIRMR Bulletin C-7.)
Compliance with the established signature procedure
expedites the process and ensures the intended QA aspects of
the internal review and approval process. This procedure works
FIP Resource Acquisition Guide 4-47
-------
Chapter 4 Acquisition Process and Procedures
Step 10/11
NOTES
Document
Requirement
Retard keeping
Requirement
best when the SIRMO and other client management personnel
have participated in developing and reviewing the APR package
and when the client has coordinated with OIRM during this
process.
Process and Results
The client submits the APR package to client management for
review, comment, and approval. A Division Director or higher
official, depending on the internal procedures of each Assistant
Administrator's organization, must approve and sign the memo.
After the package has been approved in writing by client
organization management, the client PO forwards the package
to the SIRMO for review, comment, and approval. As discussed
in Step 4, procurements exceeding the $1 million dollar
threshold as defined in EPA Order 1130.2 also require approval
from the SRO.
Upon receiving the required client organization management,
SIRMO, and, if required, SRO, approval, the client PO prepares
a cover memorandum that requests OIRM approve the package
and submit it to GSA.
Copies of the APR package, cover memos, and written
concurrences must be maintained as part of the client's
permanent acquisition file and be available for OIRM or other
official reviews when required.
Step 11 - Obtain OIRM Approval of APR
Package
OIRM approval of the APR package is obtained in this step
prior to forwarding the package to the Director of OIRM for
approval and subsequent submission to GSA. This review
serves as a QA measure to verify the accuracy and
completeness of the APR package.
FIP Resource Acquisition Guide 4-48
-------
Chapter 4 Acquisition Process and Procedures
Step 11712
NOTES
Process and Results
Approval
Requirement
Rccordkeeplng
Requirement
The client PO submits the APR package to OIRM for
approval. APR packages requiring OIRM approval should be
sent to OCSS at the following address: Chief, Oversight and
Compliance Staff, Mail Code 3401. For procurements
containing FIP hardware, software, or service, OCSS will
coordinate its review with the National Data Processing Division.
OIRM will verify the completeness of the APR package and
the correctness of the FIP resources component. If the package
is incomplete, the client will be notified and review of the APR
package will be postponed until critical documents such as the
RA, AA, IP, and required approvals are received.
Step 12 - Obtain OIRM Director Approval of
APR Package
Senior EPA approval of the APR is required in this step prior
to transmitting the package to GSA. The EPA DSO delegated
responsibility for implementing FIRMR policies and approval of
all APRs to the Director, OIRM. The Director, OIRM, therefore,
approves, signs, and transmits all agency APRs to GSA.
Process and Results
When an APR package has received all necessary EPA
concurrences and approvals, OIRM prepares a cover letter to
GSA, attaches the letter to the APR package, and submits the
package to the Director, OIRM, for signature.
The Director reviews the package, requests resolution of any
outstanding issues, approves the package, signs the cover
letter, and transmits the package to GSA.
Copies of the APR package, cover memo, GSA cover letter,
and written concurrences and approvals must be maintained as
part of the client's permanent acquisition file and be available for
OIRM or other official reviews when required.
FIP Resource Acquisition Guide 4-49
-------
Chapter 4 Acquisition Process and Procedures
Step 13
NOTES
Approval
Requirement
Document
Requirement
Step 13 - Obtain GSA Approval of APR
Package
The purpose of this step is to obtain GSA-required approval
for the DPA.
Process and Results
GSA reviews the APR package and either grants a DPA with
specified reporting requirements, asks for additional information,
or disapproves the request. When OIRM receives a request
from GSA for additional information, OCSS acts as a facilitator.
OCSS will communicate information requests, provide technical
assistance to the PO in preparing the required information, and
forward the information to GSA.
When OIRM receives notice from GSA that a DPA is
approved, OIRM notifies the client. If GSA disapproves the
APR, OIRM assists the client with the appeal process
(discussed in FIRMR Bulletin C-5), if appropriate.
Generally, GSA takes prompt action on an APR. However,
the client's ability to provide information, if requested, regarding
the regulatory compliance documentation listed in item 7 of the
APR (see Appendix F) is critical to obtaining GSA's approval.
GSA may also conduct a comprehensive review of the proposed
acquisition before issuing a DPA, and may require additional
information (e.g., request to review the analyses, acquisition
plan, or the regulatory compliance documentation listed in item 7
of the APR).
If GSA has not responded to the APR after 20 workdays, plus
5 workdays for mailing, the FIRMR allows an agency to proceed
with the procurement action as though GSA had issued the
DPA. (Note: If GSA cannot complete action on the APR within
20 workdays, it is their policy to suspend the case and notify the
agency of the action to be taken.)
GSA approval of APRs frequently is accompanied by
requirements for both pre-award and post-award reporting. The
client PO and/or CO must comply with these requirements and
FIP Resource Acquisition Guide 4-50
-------
Chapter 4 Acquisition Process and Procedures
Step 13
NOTES
submit the information to OIRM for reporting to GSA. (Step 19
contains information on post-award reports). Pre-award reports
are primarily for status and to identify problems or changes.
FIP Resource Acquisition Guide 4-51
-------
Chapter 4 Acquisition Process and Procedures
Solicitation/Step 14
NOTES
Phase 3 - Solicitation Phase
. Once GSA has granted the DPA (or not responded), EPA
continues with the acquisition. The Solicitation Phase activities
focus on preparing the various documents that make up the
internal EPA PRP, obtaining the necessary OIRM and OAM
approvals, and issuing the solicitation. Exhibit 4-6 illustrates the
steps in the Solicitation Phase.
PHASE 2
Presolicitation
^
PHASE 3
Solicitation
1
r
k-
PHASE4
Source
Selection
• t
STEP 14: Prepare PRP
STEP IS: OIRM and OAM review PRP
STEP 16: Issue Solicitation
PHASES: SOLICITATION
Exhibit 4-6
Step 14 - Prepare PRP
?
This step addresses preparation of the PRP for submission to
EPA management. This step is completed after the DPA has
been obtained from GSA, Step 13, or after determining that a
DPA is not required, Step 8.
The PRP may include, but is not limited to, standard forms,
abstracts, an SOW, proposal instructions, proposal evaluation
FIP Resource Acquisition Guide 4-52
-------
Chapter 4 Acquisition Process and Procedures
Step 14
NOTES
Coordinate
Document
criteria, procurement justification documents, and cost informa-
tion. The specific contents of the PRP depend on the nature of
the acquisition.
Process and Results
Conferring with OAM and OSDBU, as appropriate, the client
PO develops the PRP. The contents of the PRP depend on
specific client organizational requirements, OAM requirements,
and/or the client's acquisition strategy. The Procurement
Request Rationale Checklist (Checklist) in Chapter 2,
Attachment F, of EPA Contracts Management Manual lists the
documents to be included in the PRP.
The Checklist is a valuable aid in developing the PRP. The
Checklist and all applicable documents contained in the list are
required to be included in the PRP above the small purchase
threshold (currently $25,000). Documentation guidance for
small purchase acquisition is contained in Appendix H. The
Checklist also contains questions and requests for information
that apply to the specific type of procurement being conducted.
All items on the Checklist must be addressed. If an item does
not apply, mark it "not applicable."
Documents listed in the Checklist include the following:
• Procurement Request/Order (EPA Form 1900-8)
• Procurement Abstract
• Statement of Work (SOW)
• Concise Technical Proposal Instructions
• Competitive Technical Evaluation Criteria
• Justification for Other Than Full and Open Competition
(JOFOC)
• Determination and Findings (D&F) to Provide Full and
Open Competition After Exclusion of Source (see FAR 6.2)
FIP Resource Acquisition Guide 4-53
-------
Chapter 4 Acquisition Process and Procedures Step 14
NOTES i * Justification for Advisory and Assistance Services
i i
< • Justification of Need - Government-Furnished Property
! ' (GFP)
! • Quality Assurance (QA) Review Form
• Recommended Sources List
• Reports Description
• Discussion of Controls for Sensitive Contracting
• Discussion of How Procurement Fits into Overall Contrac-
ting Strategy (if required)
i
• Independent Government Cost Estimate (IGCE)
• Designation and Appointment of Project Officer/Work
' Assignment Manager/Delivery Officer (EPA Form 1900-65)
In addition to the above, the following may be included in the
. PRP, as required:
[
• TEP Members Listing
i
• Procurement Integrity Certifications for Procurement
Officials
• Request for Approval of Contractor Access to TSCA CBI
(EPA Form 7740-17)
• ADP Approval Memorandum
• Any Program-Specific Information Security Forms that
Apply
1 Appendix G contains a description of the documents listed
above, as well as guidance on topics to consider while
. developing the documents.
FIP Resource Acquisition Guide 4-54
-------
Chapter 4 Acquisition Process and Procedures Step 14
NOTES The documents in the PRP contain information that forms the
basis for many sections of the solicitation document that is
developed by OAM in Step 15. For example, the SOW
developed by the client organization is a major part of Section C
\ (Description/Specifications) of Federal solicitations and
1 contracts and contains information incorporated into Section F
(Deliveries or Performance) and potentially Chapter H (Special
Contract Requirements). The technical proposal instructions
become a part of Section L (Instructions, Conditions, and
: Notices to Bidders); and technical evaluation criteria become
part of Section M (Evaluation Factors for Award).
The quality of the documents developed by the client directly
affects OAM's level of effort, response times, and eventual
contract award. Documents that are poorly prepared or
incomplete usually result in delaying the solicitation release.
They also may cause delays upon release due to numerous
vendor questions, amendments to the solicitation in response to
vendor inquiries, evaluation problems due to vague and
ambiguous evaluation criteria, and vendor protests. They can
also result in unsatisfactory contract deliverables.
It is important to identify and quantify the performance and/or
the desired outcomes of the contractor's efforts. The
quantitative or qualitative requirements identified in the RA (see
Step 6) should be used to form the basis of these requirements
in the SOW. The SOW should not focus on detailed
; procedures, rather the solicitation's requirements should be
stated in functional terms. There should also be a clear means
of attesting to the quality of work or service performed under the
contract by EPA. Supplement #2 to OMB Circular A-76 provides
guidance on writing and administering performance SOWs for
service contracts.
Information security is highly important in the procurement
process just as it is in other areas of IRM. The client and OIRM
must be aware that many of the documents associated with the
PRP can contain confidential information. Such materials must
be protected against loss or unauthorized disclosure.
Unauthorized access to the SOW, Technical Evaluation
Criteria, IGCE, and other PRP documents containing
FIP Resource Acquisition Guide 4-55
-------
Chapter 4 Acquisition Process and Procedures
Step 14
NOTES
Requirement
Document
Requirement
procurement-specific requirements or financial data could have
serious negative consequences. Such access could provide an
unfair advantage to an individual contractor and, among other
results, force 0AM to revisit the entire procurement process and
embarrass the agency. These problems can be avoided when
the client and all authorized users of the information follow the
basic security procedures outlined in EPA's Information Security
Manual and other applicable directives cited in this guide.
The client PO is responsible for the following security actions:
• Identify the PRP's confidential documents
• Assess the risks associated with the availability, integrity,
and confidentiality of these documents
• Develop a security plan with security objectives and
handling guidelines designed to reduce all risk factors to
an acceptable level
All agency personnel that have access to the PRP are
required to adhere to the client's information security plan,
protecting all identified documents in accordance with the plan.
This includes the client PO and client, OIRM, and OAM staff that
are involved in preparation of, or handle any part of the PRP.
The client also must assess the security plans that pertain to
either data or systems that are involved in the performance of
the contract and identify any sensitivity and/or confidentiality
issues or requirements in the SOW. Contractor access to CBI is
an example of such sensitive issues. Access to FIFRA and
TSCA CBI are addressed specifically in agency policy and
procedures (see Appendix B). These security issues must be
addressed in the RA "security requirements," as discussed in
Step 6 of this guide and documented in Section 12 of the SOW
(Special Areas of Concern), as described in Appendix G.
The client PO prepares a cover memo requesting written
approval (e.g., signature lines). The client PO submits the
package to client organization management, the SIRMO, and if
the procurement request exceeds $1 million dollars, the SRO,
for approval.
FIP Resource Acquisition Guide 4-56
-------
Chapter 4 Acquisition Process and Procedures Step 14/15
NOTES ~ Client management approval must be indicated by the
i signature of a Division Director or higher official. Upon
; receiving written client management and SIRMO approvals, the
; client forwards the PRP to OIRM for review and approval.
| Exceptions to the approval process are discussed below:
i
• Acquisition of Microcomputer Hardware and Software
! • under SIRMO Delegated Purchasing Authority - SIRMOs
> are authorized to approve acquisitions of microcomputer
! hardware and software without obtaining OIRM approval.
! { This authorization is subject to several specific
i restrictions, as specified in EPA Delegation 1-1OA.
} t
• Acquisition of FIP Support Services under SIRMO
i Delegation - OIRM's QA review and approval authority for
; FIP support services acquisitions may be delegated to the
| SIRMO of an Assistant Administrator's organization.
Where this delegation has been granted, OIRM review
' and approval are not required for non-DPA FIP support
services procurement. In these cases, the SIRMO will be
CMMmat responsible for performing the QA review and approval
function. Therefore, the client PO should consult with
their SIRMO to determine whether the organization has
delegated status. OIRM's OCSS will monitor the
performance of this delegation through its FIP Acquisition
Management Review Program. (The PRA requires
agencies establish a review program to ensure the
efficient and effective management of information
resources.)
Step 15 - OIRM and OAM Review PRP
i OIRM and OAM review and approve the PRP in this step,
i thereby providing QA, reducing potential risks, and expediting
; the acquisition as efficiently as possible.
OIRM reviews the PRP to:
i
'• • Verify that requirements, specifications, tasks,
deliverables, and acceptance criteria are well structured
; and clearly described in quantitative and qualitative terms
FIP Resource Acquisition Guide 4-57
-------
Chapter 4 Acquisition Process and Procedures Step 15
NOTES • Review the cost information to verify skill categories, labor
hours, and that estimates are clearly identified and justified
• Verify the accuracy of required FIRMR and agency IRM
analyses and documentation
Packages requiring OIRM review should be sent to OCSS at
the address given in Step 11. OAM reviews the PRP for
completeness and compliance with contracting regulations.
Process and Results
Depending on whether an organization has been delegated
authority to approve the FIP resources included in the
procurement, the PRP will be handled differently during the
review. For delegated organizations, POs should simply route
the PRP to the SIRMO instead of OIRM. For non-delegated
organizations, OIRM review and approval is required in addition
to SIRMO review and concurrence.
OIRM's review of the procurement package is intended to
ensure compliance with the FIRMR and agency IRM policies.
OIRM reviews and verifies the accuracy of key analytical and
decision documents (e.g., RA, AA, IP, FIRMR Applicability
Statement, and SIRMO concurrence) for FIP resources
procurement that do not require a DPA. (For procurements
requiring a DPA, OIRM becomes involved in Step 11.) The
review also provides a QA check on important IRM acquisition-
related documents and issues (e.g., SOW, security analysis) to
ensure they reflect sound information management practices.
OIRM prefers to review the complete procurement package
but requires as a minimum the following for review and approval
of FIP support service components: (1) SIRMO approval or
concurrence signature; (2) an IGCE including a breakdown of
FIP resources by type for each task and for the entire contract;
(3) the FIRMR Applicability Statement, describing the rationale
for determination; (4) the RA, AA, and IP for the FIP resources in
the solicitation (unless previously submitted for an APR); (5) a
Conversion Study if applicable; and (6) the Statement/Scope of
Work.
FIP Resource Acquisition Guide 4-58
-------
Chapter 4 Acquisition Process and Procedures
Step 15/16
NOTES
Approval
Requirement
Record taping
Require incut
OIRM approves the PRP and returns it to the client PO.
The client PO forwards the approved PRP with OIRM
approval (or SIRMO approval memo in delegated organizations)
to OAM for review and necessary action.
OAM reviews the PRP for completeness and compliance with
contracting regulations and guidelines. OAM coordinates with
the client, OIRM (or delegated SIRMO), and OSDBU as
appropriate. After coordination and approval, OAM begins
developing the solicitation for release to the appropriate
vendors.
Copies of the PRP and all written concurrences and
approvals must be maintained as part of the client's permanent
acquisition file and be available for OIRM or other official
reviews when required.
Step 16 - Issue Solicitation
OAM issues a synopsis of the procurement in the CBD and
issues the solicitation to all vendors that request the package in
response to the CBD (see Step 14).
Process and Results
] OAM prepares and issues a synopsis in the CBD as required
by the FAR Subpart 5.2 and FIRMR Subpart 201.39.
ff
OAM then issues the solicitation to: vendors appropriate to the
type of acquisition (i.e., full and open competition, limited
competition, sole-source procurement, small business
procurement, or 8(a) procurement).
The solicitation must require the offerers to itemize their cost
proposals by individual FIP resource category.
FIP Resource Acquisition Guide 4-59
-------
Chapter 4 Acquisition Process and Procedures
Source Selection/Step 17
NOTES
Phase 4 - Source Selection Phase
The Source Selection Phase culminates the acquisition of
FIP resources by evaluating the proposals and selecting the one
that is most advantageous to the Government. There is only
one step in the Source Selection Phase as illustrated in Exhibit
4-7.
PHASE 3
Solicitation
^
PHASE 4
Source
Selection
1
r
h
PHASE 5
Contract
Administration
STEP 17: Evaluate proposals and award contract
PHASE 4: SOURCE SELECTION
Exhibit 4-7
Step 17 - Evaluate Proposals and Award
Contract
In this step, the proposals are evaluated in accordance with
the plans developed earlier in the process and the contract is
awarded.
Process and Results
The OAM and client jointly develop the "Technical Proposal
Instructions" incorporated into Section L of the solicitation and
"Technical Evaluation Criteria" incorporated into Section M of
the solicitation.
The TEP evaluates the proposals for compliance with the
technical requirements in the solicitation, under the guidance of
OAM. OAM conducts the cost evaluation.
FIP Resource Acquisition Guide 4-60
-------
Chapter 4 Acquisition Process and Procedures Step 17
; NOTES After all TEP questions and OAM contracting issues are
resolved, OAM awards the contract. Contract clauses must
; contain requirements for the vendor to itemize costs/charges for
| FIP resources by individual FIP resource category.
FIP Resource Acquisition Guide 4-61
-------
Chapter 4 Acquisition Process and Procedures
Contract Administration/Step 18
NOTES
Phase 5 - Contract Administration
Phase
After the contract is awarded, the client is responsible for
tracking and reporting the status of the contract to OIRM, the
CO, and GSA. Exhibit 4-8 illustrates steps included in the
Contract Administration Phase that are required by the FIRMR.
PHASE 3
Solicitation
PHASE 4
Source
Selection
^
^
PHASES
Contract
Administration
STEP 18: Track FIP resource costs and report status
STEP 19: Report DPA status to GSA
PHASE 5: CONTRACT ADMINISTRATION
Exhibit 4-8
Step 18 - Track FIP Resource Costs and
Report Status
This step involves contract management responsibilities,
which include tracking costs by FIP resource category and
reporting the progress and status to client program
management, OIRM, and the CO. This step is intended to
ensure that regulatory, agency, and specific-acquisition DPA
thresholds are not exceeded; to comply with DPA reporting
requirements; and to provide information for other management-
related purposes. It also applies to the FIRMR applicable FIP
resources of the contract and not to those FIP resources that
FIP Resource Acquisition Guide 4-62
-------
Chapter 4 Acquisition Process and Procedures
Step 18/19
NOTES
are incidental to the acquisition. (Note: Incidental costs do not
need to be tracked.)
Process and Results
To ensure that contract costs do not exceed FIRMR, DPA,
and contract cost limits, the client PO and CO track the usage
and total costs of PIP resources by individual resource category
over the life of the contract. The PO/CO must report all
information specified in the DPA reporting requirements to
OIRM.
In addition to compliance considerations in tracking FIP
resources expenditures, the information collected will provide
the agency with important cost data for benchmarking future
acquisitions and evaluating current contractor performance.
Unless otherwise specified by OIRM or GSA, when the
expenditures of any one FIP resource category under a contract,
reach 85 percent of the DPA threshold, the PO and CO should
evaluate the need to request an adjustment to the delegated
threshold. As a result of this evaluation, the client may need to
request a DPA or an amendment to an existing DPA. The CO
must notify OIRM of the results of this evaluation and the actions
to be taken.
Step 19 - Report DPA Status to GSA
The purpose of this step is to ensure EPA complies with GSA
established reporting requirements on the status of the DPA.
GSA places requirements for status reporting on every DPA it
issues. EPA's reporting will conform to the instructions for each
specific DPA.
Process and Results [
OIRM provides GSA with:
• Contract award information within 30 days of contract
award
• Six twelve month expenditures information
FIP Resource Acquisition Guide 4-63
-------
Chapter 4 Acquisition Process and Procedures Step 19
: NOTES * Biennial DPA status reports
• Any other information required as part of the approved
DPA
FIP Resource Acquisition Guide 4-64
-------
Appendix A. Legal Acquisition Authorities Legislation
A. LEGAL ACQUISITION AUTHORITIES
i" NOTES
| This Appendix details the Federal legislation that establishes
! the policy for the Federal Information Processing (FIP)
acquisitions and the agencies, organizations, and committees
responsible for overseeing Federal acquisitions.
Federal Legislation
T
Federal laws that directly affect the acquisition of FIP
resources include the Brooks Act, the Warner Amendment, the
Laws Paperwork Reduction (and its reauthorization), Competition in
Contracting, the Computer Security, the Office of Federal
I Procurement Policy (OFPP), and Privacy Acts. The Warner
Amendment (1981) does not affect the Environmental Protection
Agency (EPA) and is not discussed in this guide.
The Brooks Act (1965). as amended, established the
requirements for managing automated data processing equipment
\ (ADPE) and grants specific authority and responsibility to the
j General Services Administration (GSA), the Office of
Management and Budget (OMB), and the Department of
Commerce. The Act directs GSA to coordinate and provide for
: the economic and efficient purchase, lease, and maintenance of
, ADPE by Federal agencies. The Act charges OMB with fiscal
control and developing administrative and management policy for
FIP resources. Under the Brooks Act, the National Institute of
Standards and Technology (NIST), an organization within the
Department of Commerce, is responsible for providing scientific
and technological services to agencies for ADPE and for
developing and maintaining standards to maximize agencies'
ability to share computer programs and data.
The Privacy Act M974). as amended, protects information,
pertaining to individuals, that is maintained in Federal information
systems. Federal agencies and employees are responsible for
(1) maintaining the confidentiality of data included by the Act and
(2) ensuring that data concerning individuals and maintained in
Federal information systems are accurate.
FIP Resource Acquisition Guide A-1
-------
Appendix A. Legal Acquisition Authorities ' Legislation
NOTES ' The Paperwork Reduction Act (PRA1 (1980). as amended.
' was enacted to accomplish the following:
• Minimize the Federal paperwork burden
\
1 i • Minimize the cost to the Federal Government of controlling
; information
• Maximize the usefulness of information collected by the
Federal Government
{ • Make uniform Federal information policies and practices
• • Ensure that automated data processing (ADP) and
telecommunications technologies are acquired and used to
improve service and program management, increase
productivity, reduce waste and fraud, and reduce the
information processing burden for the Federal Government
and for persons who provide information to the
Government
i
• Ensure that the control of information by the Federal
Government is consistent with applicable laws relating to
the Privacy Act
The PRA prescribes that each Executive agency designate a
! senior official to systematically inventory information systems
and to develop procedures for implementation of the Act. The
OMB Office of Information and Regulatory Affairs has overall
authority for implementation of the PRA and defines
requirements in OMB Circular A-130.
The Paperwork Reduction Reauthorization Act (1986)
expands the Brooks Act definition of ADPE to include the
merging of FIP, telecommunications, and related technologies.
The Act combined the old ADP and Federal
Telecommunications Funds into one Information Technology
Fund (ITF). Also under the Act, the GSA Board of Contract
Appeals (GSBCA) was given permanent jurisdiction over ADP
protest resolution.
FIP Resource Acquisition Guide A-2
-------
Appendix A. Legal Acquisition Authorities Legislation
' NOTES The Competition in Contracting Act (CICA) (1984) mandates
; a policy of full and open competition. The CICA requires that all
i ! responsible vendors be allowed to compete to receive a contract
) award. This means that a Statement of Work (SOW) or
; specifications must not be restrictive (i.e., not be written around
one vendor's product or qualifications). The Federal Acquisition
Regulation (FAR) Part 6 provides seven exceptions to this rule,
which must be justified based on specific criteria and approved
by the Office of Acquisition Management (OAM).
<,
The CICA also reinforces the Government's policy of placing
a proportion of its acquisitions, including contracts and
subcontracts, with small and small disadvantaged businesses.
!
The Computer Security Act (1987) contains provisions for
protecting computer-related assets (e.g., hardware, software,
and data). The Act assigns responsibility for developing
computer security guidelines and standards to NIST. The Act
i also requires agencies to identify systems that contain sensitive
: data and develop a security plan for each of them.
: The Office of Federal Procurement Policy Act (1974) contains
| provisions regarding inherently Governmental functions and
procurement integrity that apply to contractors and Government
officials involved in Federal procurements. Failure to comply
with this act could result in administrative actions and/or
; contractual, civil, and criminal penalties.
• Inherently Governmental Functions - OFPP Order 92-1
and EPA Order 1900.2 list the types of activities that
cannot be performed by vendors. (OFPP 92-1: Federal
i , Register, Volume 57, Number 190, pp. 45096-45103,
September 30,1992.)
i '
• Procurement Integrity - The procurement integrity
provisions of the OFPP Act state that procurement
I ; officials shall not:
i
' 0 Solicit or accept any promise of future employment with
! a "competing contractor"
FIP Resource Acquisition Guide A-3
-------
Appendix A. Legal Acquisition Authorities Oversight
NOTES ^ Ask f°r or accePt any money or thing of value from a
"competing contractor"
0 Disclose any proprietary or source selection
information to unauthorized individuals
Oversight Organizations
The following Government organizations have primary
authority for overseeing various aspects of FIP resource
acquisitions.
General Services Administration - GSA coordinates and
provides for the economic and efficient purchase, lease, and
maintenance of ADPE by Federal agencies. GSA issues
changes to the Federal Information Resources Management
Regulation (FIRMR) and conducts other acquisition activities,
such as granting delegations of procurement authority (DPAs)
and conducting Information Resources and Procurement
Management Reviews. GSA also issues the Federal ADP and
Telecommunications Standards Index which contains a listing of
Federal standards and terminology for use in solicitations.
GSA is prohibited from impairing or interfering with an
agency's determination of its data processing requirements,
including developing specifications and selecting types and
configurations of equipment. GSA also cannot control an
agency's use of the equipment.
General Services Administration Board of Contract Appeals -
The GSBCA is responsible for resolving disputes relative to
contracts with GSA, the Department of the Treasury, the
Department of Education, the Department of Commerce, and
other independent Government agencies such as EPA. The
Board also is empowered to hear and decide protests arising out
of ADP procurements Governmentwide. Although the Board is
located within the agency, it functions as an independent
tribunal.
FIP Resource Acquisition Guide A-4
-------
Appendix B. Regulatory & Reference Documents/Sources
Public Law/FAR
B. REGULATORY AND REFERENCE
DOCUMENTS/SOURCES
NOTES
Lowe
Regulations
This Appendix provides a list of Federal and Environmental
Protection Agency (EPA) documents and programs cited in this
guide or identified as providing valuable information or services
relative to Federal Information Processing (FIP) acquisitions.
Specific parts of the Federal Acquisition' Regulation (FAR) and
the Federal Information Resources Management Regulation
(FIRMR) applicable to the activities included in this guide are also
listed.
Public Law
• PUBLIC LAW 99-500
i-
Federal Acquisition Regulation
Individual subscription to the FAR can be ordered by writing or
calling:
Superintendent of Documents
U.S. Government Printing Office (GPO)
Attn.: Order Desk
Washington, DC 20401
(202) 783-3228
The FAR is also available at the EPA Headquarters Library.
Sections of the FAR pertinent to FIP resources acquisitions
include:
FAR PART 1
FAR PART 2
FAR PART 4
FAR PART 6
FAR PART 7
FAR PART 13
FAR PART 14
FAR PART 15
FAR PART 16
FAR PART 17
FAR PART 34
FAR PART 37
FAR PART 39
FAR PART 45
FIP Resource Acquisition Guide B-1
-------
Appendix B. Regulatory & Reference Documents/Sources
FIRMR/OMB
NOTES
Regulations
Federal Information Resources
Management Regulation
Sections of the FIRMR pertinent to FIP resources acquisitions
include:
FIRMR 201-1
FIRMR 201-2
FIRMR 201-3
FIRMR 201-4
FIRMR 201-5
FIRMR 201-6
FIRMR 201-7
FIRMR 201-8
FIRMR 201-9
FIRMR 201-10
FIRMR 201-11
FIRMR 201-12
FIRMR 201-13
• FIRMR BULLETIN A-1
• FIRMR BULLETIN C-5
• FIRMR BULLETIN C-6
FIRMR 201-14
FIRMR 201-15
FIRMR 201-16
FIRMR 201-17
FIRMR 201-18
FIRMR 201-19
FIRMR 201-20
FIRMR 201-21
FIRMR 201-22
FIRMR 201-23
FIRMR 201-24
FIRMR 201-39
FIRMR BULLETIN C-7
FIRMR BULLETIN C-10
Office of Management and Budget
Circulars
The Office of Management and Budget (OMB) Circulars and
Bulletins can be obtained by writing or calling:
Executive Office of the President (EOF)
726 Jackson Place, NW
Room 2200
Washington, DC 20503
(202) 395-7332
OMB Circulars pertinent to FIP resources acquisitions
include:
Regulations
FIP Resource Acquisition Guide B-2
-------
Appendix B. Regulatory & Reference Documents/Sources
FIPS PUBs/GSA PUBs
NOTES
Regulations
OMB CIRCULAR A-11
OMB CIRCULAR 109
OMB CIRCULAR 120
OMB CIRCULAR 130
OMB CIRCULAR A-76
OMB CIRCULAR A-94
OMB CIRCULAR A-104
SUPPLEMENT NO. 2 TO OMB CIRCULAR A-76
Federal Information Processing
Standards and Guidance
The Federal Information Processing Standards Publications
(FIPS PUBs) can be obtained by writing or calling:
National Technical Information Service (NTIS)
Attn.: Document Sales
5185 Port Royal Road
Springfield, VA 22161
(703) 487-4650
Most FIPS PUBs also are available at the EPA Headquarters
Library. FIPS PUBs pertinent to FIP resources acquisition
include:
• FIPS PUB 38
FIPS PUB 64
General Services Administration
Publications
Copies or information regarding the General Services
Administration (GSA) documents referenced in this guide (see
below) can be obtained from GSA's Information Resources
Management (IRM) Reference Center, at:
IRM Reference Center (KML)
General Services Administration
18th and F Street, NW
Washington, DC 20405
(202) 501-4860
FIP Resource Acquisition Guide B-3
-------
Appendix B. Regulatory & Reference Documents/Sources GSA PUBs
! NOTES "• GSA publications pertinent to FIP resource acquisitions
! ! include:
: |
• ' • ADP and Telecommunications Standards Index
I
! • A Guide for Acquiring FIP Support Services
i
| • A Guide for Acquiring Systems Integration Services
! • A Guide for Acquiring Maintenance Services
• A Guide for Acquiring Commercial Software
! i
; • A Guide to Alternate Requirements Analysis
Methodologies
i
• A Guide for Contracting Officers'Technical
Representatives
; • A Guide for Evaluating Proposals and Bids
• A Guide for Requirements Analysis and Analysis of
Alternatives
i
• A Guide for Using GSA's Schedule Contracts for FIP
| Resources
• GSA Standard Solicitation Documents
i
] • Overview Guide: Acquisition of Information Resources
• Performing a Requirements Analysis for Acquisition of FIP
; ' Equipment
• Source Selection Procedures: Lessons Learned
! • Source Selection Procedures Handbook
', Information regarding GSA's Electronic Bulletin Board
Service (EBBS) containing current IRM acquisition information is
available from GSA's Evaluation and Analysis Branch at (202)
501-4305.
FIP Resource Acquisition Guide B-4
-------
Appendix B. Regulatory & Reference Documents/Sources
EPA PUBs
NOTES
Regulations
Regulations
Regulation
Information regarding GSA's On-Line Schedule System
(OSS), an electronic bulletin board and data base system
providing access to IRM schedule contractor's catalogs, is
available from GSA's Planning and Support Division at (202)
501-7510.
Environmental Protection Agency
EPA Order
• EPA Order 1510
EPA Regulations
EPA regulations pertinent to FIP resources acquisition
include:
EPAAR 552.235
EPAAR 1505.27
EPAAR 1506
EPAAR 1506.371
EPAAR 1510
• EPAAR 1515.6
• EPAAR 1519
• EPAAR 1534
• EPAAR 1552.215
EPA Manuals, Handbooks, and Guides
EPA manuals, handbooks, and guides pertinent to FIP
i resources acquisition include:
i
i
• Bankcard Training and Call Ordering Officer Course
Manual
; • Cardholder Instructions, The U.S. Government Credit Card
• Contracts Management Manual
• Delegations Manual
Federal Information Processing (FIP) Resource
Acquisition, Interim Guidance
Information Security Manual
FIP Resource Acquisition Guide B-5
-------
Appendix B. Regulatory & Reference Documents/Sources Miscellaneous
NOTES " Interagency Agreement Policy and Procedures
' Compendium
• IRM Policy Manual
[ • Preferential Procurement Program Handbook for Project
Officers, Contract Officers, and Small Business Specialists
• Project Officers's Handbook
• Property Manual
• Risk Analysis Guideline
E
! • Small Purchases, A Guide for Program Offices
I • Strategic and Multiyear Plan Document
' • System Design and Development Guidance Manual
• Toxic Substances Control Act (TSCA) Confidential
Business Information Security Manual
Miscellaneous
Miscellaneous publications pertinent top FIP resource
acquisitions include:
• Commerce Business Daily (CBD)
, • Federal Telecommunications Standards (FED-STDS)
• National Data Processing Division (NDPD) Operational
1 Policies Manual
• Office of Acquisition Management (OAM) Guide for
; Preparing Independent Government Cost Estimates
• Office of Administration and Resources Management
(OARM) Procurement Policy Notice 93-07
• Office of Federal Procurement Policy (OFPP) Order 92-1
FIP,. Resource Acquisition Guide B-6
-------
Appendix B. Regulatory & Reference Documents/Sources Miscellaneous
: NOTES ' ' Office of Information Resources Management (OIRM)
j I Delegation 1-1OA
! i
I |
I ! • Program Specific Information Security Manuals
i
FIP Resource Acquisition Guide B-7
-------
Appendix B. Regulatory & Reference Documents/Sources
(This page intentionally left blank.)
FIP Resource Acquisition Guide B-8
-------
Appendix C. Identifying FIP Support Services
Contract Purpose
C. IDENTIFYING FIP SUPPORT SERVICES
NOTES
This Appendix provides guidance on identifying Federal
Information Processing (FIP) support services. The questions
from FIRMR Bulletin A-1 that are refered to below are provided in
Exhibit 4-4.
Identify the Intent/Purpose of the
Contract or Task
The task requirements, labor categories, and deliverables
serve as a guide in making the FIP, incidental FIP, or non-FIP
resource determination along with the intent or purpose of the
task.
It is easy to identify FIP resources when the Environmental
Protection Agency (EPA) needs information technology (IT)
systems built or maintained or staffing of a computer facility or
services center. Programmers, computer analysts, computer
operators, data entry clerks, and other automated data
processing (ADP)-related categories are clearly FIP support
services.
If a task requirement is described in ADP terms, historically
understood as an ADP-related function or service, or clearly for
production of an ADP-related product for use by EPA or user
designated by EPA, then the effort associated with that task is a
FIP resource.
If the answer to the Federal Information Resources
Management Regulation (FIRMR) Bulletin A-1 guidance question
1 is "Yes," the FIRMR is applicable to the contract action. If these
qualifiers are not present, the effort may not be a FIP support
service.
If the intent or purpose is to provide a hon-ADP related
professional service or produce a non-ADP related product
involving the use of ADP-related equipment or services or agency
FIP Resource Acquisition Guide C-1
-------
Appendix C. Identifying FIP Support Services
Contract Purpose
NOTES
FIP resources, further examination of the task or requirement is
needed.
Generally, when non-ADP functions or services are required
(e.g., scientific or engineering analysis and reports) and the
contractor produces a product (e.g., an analytical report) or has
discretion to perform a service using ADP resources, FIP
resources are incidental to the contract or task. In this case,
the answer to FIRMR Bulletin A-1 guidance question 1 is "No"
since there is no delivery of FIP resources, question 2 is "Yes"
as the task depends on FIP resources, and question 3 is "No"
since the contractor has discretion in the acquisition and
management of FIP resources. Based on answers 1 and 3, the
FIRMR does not apply.
As another example, a task requires chemical
information/data submission review, development of an abstract
of the information/data submission, and recording of the abstract
into an EPA information system. If, as in this example, the effort
to "record" the abstract on an automated system is intended to
be accomplished by a chemist and is typical of what a chemist
would do, then the computer is simply considered a tool and the
"recording" is incidental to the intent or purpose.
However, when the "recording" is intended to be
accomplished by a data entry clerk, is a significant effort in the
overall task, does not require specialized subject matter
expertise, and/or is not associated with development of the
abstract, a data entry FIP support service capability is
suggested. The FIRMR is applicable to the contract action for
this type of support service and estimated costs are categorized
as a FIP support service resource in the cost estimate. The
labor category requirements section (if appropriate for the
contract type) of the solicitation package should also reflect this
need. The answer to FIRMR Bulletin A-1 guidance question 1 is
"Yes" since the task requires data entry support services.
The intent of the contract/task, good judgement, and a clear
statement of work (SOW) are key to identifying FIP resources,
computing the "total value" of those FIP resources over the life
of the contract and determining the applicability of the FIRMR to
the procurement action.
FIP Resource Acquisition Guide C-2
-------
Appendix C. Identifying FIP Support Services
Nature of Work
NOTES
Consider the Traditional Nature of the
Work or Task (i.e., Pre-Computer Era)
The previous example emphasized the importance of
determining whether the FIP resources in a solicitation are the
focus of the solicitation or simply a tool to be employed in
performing the work of the solicitation. When FIP resources
(e.g., computer or software) are used exclusively as tools to
perform non-FIP work, they are rarely considered FIP or FIRMR
applicable. Considering the traditional nature of the work or
task, pre-computer era is a good guide for making the FIP, non-
FIP assessment.
For example, before the computer age, clerks used Address-
O-Graph machines, address plates, or card files to maintain a
mailing list. Now the most efficient method of maintaining a
mailing list is by using a personal computer (PC) with assorted
off-the-shelf software. If a task requires maintenance of a
mailing list this is still a clerical function even if a PC is used,
and the time supporting this task is not a FIP support service.
The answers to FIRMR Bulletin A-1 guidance question 1 is
"No" since there is no delivery of FIP resources, question 2 is
"Yes" because the task depends on use of FIP resources; and
question 3 is "No" assuming the task requirements do not
restrict the contractors discretion in acquisition and management
of FIP resources. Therefore, the task is not a FIP resource and
the FIRMR does not apply.
Note that the answer to FIRMR Bulletin A-1 guidance
question 2 depends on the size of the effort and specific
requirements. If "No" is appropriate, additional questions are
not required since no FIP issues are present.
Again, a support service is identified as a FIP support service
only when the intent of the task is clearly ADP-related or the
labor category is traditionally ADP-related (e.g., data entry clerk,
programmer, computer analyst).
FIP Resource Acquisition Guide C-3
-------
Appendix C. Identifying FIP Support Services
Less Obvious
NOTES
Consider Less Obvious FIP Support
Services When in Doubt
When the intent of a contract or contract task is unclear on
FIP resource issues, or when the contract's SOW language fails
to clearly address requirements or mention computer-related
requirements, the identification of FIP support services become
more difficult.
Listed below are three contract/task scenarios to help identify
less obvious FIP support services.
• Scenario 1 - Chemical/engineering professionals are
required to provide expertise necessary in the
development of a new computer simulation model for EPA.
Deliverables associated with this task are software and
documentation. The answer to FIRMR Bulletin A-1
guidance question 1 is "Yes" because this is clearly a FIP
support service task. However, the chemists/engineers
are required to provide only scientific/engineering
expertise.
Although the intent of the task is development of a
computer-based model, the chemist/engineers are not
tasked with performing any FlP-related tasks. Therefore,
their efforts are not considered part of FIP support
services.
If, however, the contractor proposes, and subsequently
uses, chemical or engineering professionals that are
accomplished programmers to actually develop the
program's software, then the time these persons devote to
programming is accountable as a FIP support service. If
the efforts required to provide technical and programming
expertise are so closely related they cannot be reasonably
separated, the total time expended for this task is counted
as a FIP support service resource. If the efforts are
separable, only the time expended on software
development is considered a FIP support service resource.
FIP Resource Acquisition Guide C-4
-------
Appendix C. Identifying FIP Support Services
Less Obvious
NOTES
• Scenario 2 - An office has a need for services to staff a
records or dockets unit.
Clearly the overall intent of this need is not FlP-related.
When a personal computer is used to perform what was
once a manual records management function, then the
computer is essentially a replacement tool for pen and
paper records and the FIP resource is considered
incidental to performance of the task and is not a FIP
support service.
However, if a contractor is also tasked with modifying the
indexing software used to manage records, the intent of
the task is to provide FIP support services. Since, under
this condition, this would involve "delivery" of FIP
resources, the answer to FIRMR Bulletin A-1 guidance
question 1 becomes "Yes, and the FIRMR is applicable to
this task and needs to be estimated as a FIP resource.
Note: The FIRMR only applies to the software
development performed under the acquisition task.
• Scenario 3 - EPA wishes to contract for scientific and/or
engineering regulatory analyses of data, including delivery
of reports based upon the analyses. The contract requires
the contractor to use EPA developed and certified software
to perform the regulatory analysis. The software
requirement dictates that the contractor obtain a Novell-
based local area network (LAN). The total cost of the
contract over its life is an estimated $3,000,000; the total
cost for the contractor to establish and maintain the LAN
over the contract life is an estimated $200,000.
The intent or purpose of the contract is to provide
scientific and/or engineering analysis of data and
analytical reports. However, the contractor will provide
FIP services to operate the software. EPA has taken the
discretion away from the contractor as to the acquisition of
FIP software by requiring specific proprietary software.
The answers to FIRMR Bulletin A-1 guidance question 1 is
"No" since EPA is not acquiring FIP resources; question 2
is "Yes" because the principal task depends on EPA
FIP Resource Acquisition Guide C-5
-------
Appendix C. Identifying FIP Support Services Less Obvious
NOTES ' furnished software and software system operation;
question 3 is "Yes" since the proprietary software
requirement limits contractor discretion; and question 4 is
"Yes" because the requirement for FIP resources is
explicit. The "Yes" answer to question 4 clearly indicates
the FIRMR does apply to the contract action.
The estimated costs of all FIP resources is $200,000 over the
contract life. Since this is below the FIRMR-authorized $2.5
million applicable ceiling, the FIRMR applies to part of the
contract but EPA does not have to obtain a GSA delegation of
procurement authority (DPA).
FIP Resource Acquisition Guide C-6
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Appendix D. Key References and Authorities by Step
Stepl
D. KEY REFERENCES AND AUTHORITIES BY
STEP
r
NOTES
This Appendix lists the key references and authority
documents for each Phase and Step of the acquisition process.
The Environmental Protection Agency (EPA) classifies,
regulatory documents into four categories:
• Policy - Provides direction and addresses the "what" and
"why." It is a basic statement of principles. Policies include
authorities, identify key organizations responsible for
implementation, and are considered by EPA as mandatory.
• Standards - Provide a system of measurement and a basis
of comparison by which adherence to policy can be
determined.
• Procedures - Explain how to perform work to comply with
policy and to achieve applicable standards. They often
involve prescribed documentation and work flows and are
considered by EPA as mandatory.
• Guidance - Documents recommend various approaches or
formats, but are not mandatory.
PHASE 1 - INITIAL PLANNING PHASE
Step 1 - Identify Information and FIP Resource
Needs
FIRMR 201-18 (po//cy) prescribes policies and procedures
regarding agency planning and budgeting for the Federal
Information Processing (FIP) resources, the requirement for a
5-year plan for meeting the agency's information technology (IT)
needs, and submission of the 5-year plan to the General Services
Administration (GSA).
FIP Resource Acquisition Guide D-1
-------
Appendix D. Key References and Authorities by Step Step 1
NOTES FIRMR 20,1-20.305 (po//cy) discusses desirability of
; separating FIP resources from non-FIP resources when
; contracting.
The agency's or client organization's strategic and multiyear
plans (guidance) provide the high-level strategy for the
Information Resources Management (IRM), including budgeting
and FIP resources acquisitions.
; OMB Circular A-130 (policy) requires agencies to establish a
strategic planning process for acquiring IT.
I EPA Directive 2100 (henceforth referred to as the EPA IRM
\ Policy Manual) (policy) prescribes IRM functions such as
; mission-based planning, budgeting, and acquisition
planning. The manual also establishes the principles that
govern EPAwide planning, and defines the roles and
responsibilities for implementing those principles.
, EPA System Design and Development Guidance Manual
(guidance) provides information on how to document a problem
and justify the need for an IT solution. It also provides guidance
for the acquisition and management of IT.
FIRMR Bulletin A-1 (guidance) will help client organizations
, structure their thinking in determining needs for FIP resources.
Bulletin A-1 provides the following:
: • Definitions and examples of FIP resources
i
• Information regarding FIRMR applicability, policy, and
exceptions
! i
1 • Examples of FIRMR applicability when contracting for FIP
i resources
FIP Resource Acquisition Guide D-2
-------
Appendix D. Key References and Authorities by Step Step 2
NOTES Step 2 - Reconcile Needs with Existing
Budgets, Resources, and Plans;
| Update Plans as Needed
i
FIRMR 201-18 (po//cy) requires agencies to develop a 5-year
| plan for meeting IT needs that reflect current and future program
| ' and mission needs. The plan must reflect budget constraints,
! form the basis for budget requests to OMB, serve as a basis for
; requirements analyses, be updated as needed (at least
| annually), and ensure participation of program areas, IRM
. organizations, and contracting and budgeting functions. It also
requires agencies to "ensure that acquisition of FIP resources is
! in accordance with the updated 5-year plan."
i
OMB Circular A-11 (po//cy) provides detailed instructions on
preparing budget estimates, and requires budget justification for
data processing and telecommunications resources based on
mission need.
OMB Circular A-130 (policy) requires agencies to "establish
multiyear strategic planning processes for acquiring and
| operating IT that meet program and mission needs, reflect
1 budget constraints, and form the basis for their budget
requests."
i EPA IRM Policy Manual (policy), Chapter 2, implements the
FIRMR requirements for EPA to effectively plan for acquiring
information resources and technology and to tie the planning
: process to the budget process. It identifies the Senior
Information Resources Management Official (SIRMO) as the
responsible official for ensuring integration of budgets with IRM
plans for their programs.
EPA Interagency Agreement Policy and Procedures
Compendium (policy and guidance) provides guidance on the
interagency agreement process and documentation
requirements.
FIP Resource Acquisition Guide D-3
-------
Appendix D. Key References and Authorities by Step Step 3
NOTES Step 3 - Document Mission Needs, Feasible
Solutions, and FIRMR Applicability
: FIRMR 201 (policy) describes alternative sources for
acquiring FIP resources as follows:
• Procurement new (by new or existing contract)
0 Negotiated-(FIRMR 201-39.15; Bulletin C-4)
0 Sealed Bid - (FIRMR 201-39.14; Bulletin C-4)
-------
Appendix D. Key References and Authorities by Step Step 3
NOTES * GSA Mandatory-for-Use Programs - FIRMR
201.20.203-1; 201-24.000 and .001; 201-24.1;
; Bulletins B-4 and C-15)
• GSA Mandatory-for-Consideration Programs - FIRMR 201-
24.000; 201 -24.001; 201 -24.2)
• Resource Sharing-FIRMR 201-20.203-1; 201-20.305-
1; Bulletins C-1 (Telecomm), C-11 (Sharing of
Automatic Data Processing (ADP) Resources), and C-
15 (Mandatory Telecomm)
FIRMR 201-1 (policy) prescribes the extent to which the
| FIRMR applies to (among other things) the acquisition of FIP
' resources.
t,
FIRMR Bulletin A-1 (guidance) defines and provides
! examples of FIP resources and FIRMR applicability.
FIRMR 201-20 (po//cy) requires agencies to base
i requirements on mission needs. EPA's IRM Policy Manual ;
requires EPA managers to plan, budget, acquire, maintain, and
operate FIP resources in a manner that meets the documented
mission needs of the various programs within EPA.
FAR Part 34 (po//cy) describes acquisition policies and
procedures for use in acquiring major systems consistent with
OMB Circular A-109.
GSA Acquisition of Federal Information Processing
Resources Overview Guide (guidance) provides guidance on
the Federal acquisition process for FIP resources.
OMB Circular A-109 (policy) primarily addresses major
information systems. Circular A-109 complements the FIRMR
by prescribing that agencies express needs in terms based on
an analysis of the agency's mission.
EPAAR 1534 (policy} implements FAR part 34 and OMB
Circular A-109 in EPA by prescribing agency policies,
procedures, and acquisition strategy for major systems. EPAAR
1534 also defines a major system, as well as other key terms.
FIP Resource Acquisition Guide D-5
-------
Appendix D. Key References and Authorities by Step Step 4/5
NOTES - EPA Interagency Agreement Policy and Procedures
Compendium (po//cy) provides guidance on developing
! agreements between agencies for sharing of FIP resources.
! EPA System Design and Development Guidance Manual
, (guidance) provides information on how to document a problem
and justify the need for an IT solution. It also provides guidance
, for the acquisition and management of IT. It includes guidance
! on identifying and evaluating feasible options.
FIPS PUB 64 (standard) is a valuable reference for preparing
a mission needs statement, feasibility study, or cost/benefit
analysis. Although this document is specifically targeted at
software, the guidance contained in it can readily be adapted to
other FIP resources.
Step 4 - Obtain Internal Client Organization
Approvals to Proceed
EPA IRM Policy Manual (policy) designates SIRMOs1
responsibilities for "directing and managing officewide
information resources planning and budgeting," and for assuring
that the information systems and technology acquisitions within
their organizations comply with Federal and EPA policies and
. regulations.
Step 5 - Begin Acquisition Planning
FAR Part 2 (policy) states the "acquisition begins at the point
where agency needs are established and includes the
description of requirements."
FAR Part 7 (policy) requires agencies to begin acquisition
planning "as soon as the agency need is identified, preferably
well in advance of the fiscal year in which contract award is
necessary." Part 7 discusses the acquisition planning process
and the content of written acquisition plans in some detail.
EPA Contracts Management Manual (policy), Chapter 1,
, prescribes EPA acquisition planning requirements.
FIP Resource Acquisition Guide 0-6
-------
Appendix D. Key References and Authorities by Step
Step 6
NOTES
EPA Preferential Procurement Program Handbook For
Project Officers, Contract Officers, and Small Business
Specialists (policy) establishes policies and procedures, and
assigns responsibilities for implementing the Small and
Disadvantaged Business Utilization Program.
FIRMR Bulletin C-5 (guidance) describes instructions for
preparing an Agency Procurement Request (APR). The
"contracting approach" addressed in the Acquisition Plan is an
item that must be addressed in the APR.
EPA Project Officer's Handbook (guidance) contains a
"Suggested Acquisition Planning Checklist" in Chapter 3.
GSA has issued a number of valuable guides pertaining to
FIP acquisitions (guidance). A list of current titles is provided in
Chapter 1, of this guide.
i
In addition to the acquisition guides, GSA's Office of
Acquisition Policy has published a pamphlet entitled Source
Selection Procedures: Lessons Learned (guidance).
PHASE 2 - PRESOLICITATION PHASE
Step 6 - Determine Mission-Based Functional
Requirements and Analyze
Alternative Solutions
The following documents pertain to a Requirements Analysis
(RA):
• FIRMR 201-20.1 (policy) provides guidelines for
performing an RA and the approach that should be taken
to describe requirements.
• OMB Circular A-130 (policy) compliments the FIRMR by
requiring agencies to "...document the requirements that
each major information system is intended to serve...".
FIP Resource Acquisition Guide D-7
-------
Appendix D. Key References and Authorities by Step Step 6
NOTES * EPA System Design and Development Guidance Manual
(guidance) provides information on how to document a
problem and justify the need for an IT solution. It also
provides guidance for the acquisition and management of
1 IT. It includes guidance on identifying and evaluating
; feasible options.
• EPA IRM Policy Manual, Ch. 2(5e) and Ch. 3(5) (po//cy),
discuss requirements-related considerations.
• EPA Information Security Manual (po//cy) will assist the
client in determining security requirements.
• EPA Risk Analysis Guideline (Temporary Directive) can
assist in analyzing risk of information systems and
automated data processing (ADP) platforms.
• FIPS PUB 38 (standard) provides guidelines on,
among other topics, development of functional
requirements documents.
• GSA's Guide to Alternative Requirements Analysis
Methodologies (guidance) describes non-traditional
methods of performing an RA, such as re-engineering, the
Delphi Method, and interactive design methods.
• GSA's Performing A Requirements Analysis for Acquisition
of FIP Equipment (guidance) follows the FIRMR and life
cycle management guidelines and also describes how to
document the RA. Although the focus of this guide is FIP
equipment, it may be useful when performing RAs for other
FIP resources.
The following documents pertain to an Analysis of
Alternatives (AA):
• FIRMR 201-20.2 (policy) provides guidelines for
performing an AA, including performing a cost/benefit
analysis.
FIP Resource Acquisition Guide D-8
-------
Appendix D. Key References and Authorities by Step Step 6
[ NOTES i • FAR Subpart 7.105(b) (policy) discusses the need for
; j market surveys when analyzing alternatives. A market
j ; survey is one aspect of performing an AA.
! i
( I
! | • EPAAR (policy) Subsection 1505.270 pertains to market
i ! surveys and Subsection 1506.371 addresses the "conduct
| of market surveys."
i • OMB Circular A-76 (po//cy) requires agencies to determine
! whether commercial activities should be performed under
contract with commercial sources or in-house using
Government facilities and personnel.
• OMB Circular A-94 (policy), Guidelines and Discount
; t Rates for Benefit-Cost Analysis of Federal Programs, can
be useful to clients performing an AA.
i
• OMB Circular A-130 (policy) compliments the FIRMR by
requiring agencies to "seek to satisfy new information
! needs through...interagency or intergovernmental sharing
\ of information..; and to acquire IT in a competitive manner
that minimizes total life cycle costs."
•
| • FIPS PUB 64 (standard) is a valuable reference for
i preparing a cost/benefit analysis, including a description of
alternatives.
• OMB Circular A-11 (policy) is the basis for the Office of
Information Resources Management's (0IBM's) integrated
planning and budgeting data call. This is a useful
reference for planning and accounting for cost estimates
; derived from the AA. This will allow for easier coordination
of AA cost data with the planning process and responding
to OMB requests.
!
: • GSA's Preparing Software Conversion Studies (guidance),
is helpful in identifying software conversion costs. The
handbook is available through the GSA's Office of
Technical Assistance, Federal Software Management
: Support Center.
FIP Resource Acquisition Guide D-9
-------
Appendix D. Key References and Authorities by Step Step 7/8
NOTES i GSA's Guide for Requirements Analysis and Analysis of
Alternatives is pertinent to both the RA and AA.
!
Step 7 - Begin Implementation Planning
; ! FIRMR 201-20.3 (po//cy) prescribes polices and procedures
' for the IP; addresses using FIP Standards (FIPS), Federal
, Telecommunications Standards (FED-STDS), interim standards,
and agency-unique standards; and addresses capability and
performance validation requirements.
EPA Information Security Manual (po//cy) may be useful when
considering implementation issues. Also refer to any program-
! specific information security manuals that apply.
: GSA's ADP and Telecommunications Standards Index
i (guidance) lists Federal and industry standards, and provides
terminology that can be used in solicitations.
Step 8 - Determine Requirement for DPA
FIRMR 201-20.305 (po//cy) contains information pertaining to
delegation of procurement authority (DPA) types and
applicability, cost thresholds, and other criteria.
The following FIRMR Bulletins contain additional information
; on topics in this section, as indicated, as they apply to DPA
requirements.
i
• FIRMR Bulletin C-5 (Delegation of GSA's Exclusive
Procurement and Multi-year Contract Authority)
\ ' (guidance).
i
i
• FIRMR Bulletin C-6 (Federal Information Resources
Management Review Program) (guidance).
i • FIRMR Bulletin C-7 (Trail Boss Program) (guidance).
FIP Resource Acquisition Guide D-10
-------
Appendix D. Key References and Authorities by Step Step 9/10/11
NOTES Step 9 - Prepare APR
- i
EPA IRM Policy Manual (po//cy) prescribes IRM functions
| such as mission-based planning, budgeting, and acquisition
, planning. The manual also establishes the principles that
govern agencywide planning, and defines the roles and
responsibilities for implementing those principles.
FIRMR Bulletin C-5 (guidance) describes the procedures for
requesting a delegation of the General Services Administration's
exclusive procurement authority for a specific acquisition.
Attachment A of Bulletin C-5 provides the instructions for
preparation of an APR.
FIRMR Bulletin C-7 (guidance) discusses "Trail Boss" FIP
resource acquisitions.
Step 10 - Obtain Internal Client Organization
Approvals of APR Package
EPA IRM Policy Manual (policy), Chapters 1,4, and 6,
address IRM, software management, and automated data
processing equipment (ADPE) resources management
respectively. The IRM Policy Manual provides policy on IRM-
related management controls, reviews, and approvals.
EPA Delegations Manual (po//cy), Delegation 1-84,1-10, and
1-1OA, assign OIRM responsibility and authority for FIP
resource acquisition and management.
Step 11 - Obtain OIRM Approval of APR
Package
EPA IRM Policy Manual (policy), Chapters 1, 4, and 6,
address IRM, software management, and ADPE resources
management respectively. The EPA IRM Policy Manual also
establishes the principles and requirements governing these FIP
resources and designates OIRM responsibility for managing
these resources.
FIP Resource Acquisition Guide D-11
-------
Appendix D. Key References and Authorities by Step Step 12/13/14
NOTES EPA Delegations Manual (po/fcy), Delegation 1-84,1-10, and
1 1-1OA, assign OIRM responsibility and authority for FIP
! resource acquisition and management.
i
Step 12 - Obtain OIRM Director Approval of
APR Package
i
FIRMR Subpart 201-2 and Subpart 201-20.35 discuss the
role of the Designated,'Senior Official (DSO).
EPA Delegations Manual (po/rcy), Delegation 1-84 prescribes
; that the DSO is responsible for implementing FIRMR policies
and approving all APRs, Delegation 1-84 assigns OIRM
responsibility for FIP resource acquisition and management.
, f
EPA IRM Policy Manual (po//cy) describes OIRM
responsibility for FIP resource acquisition and management.
Step 13 • Obtain GSA Approval of APR
Package
*
FIRMR Subpart 201-20.305 (po//cy) discusses GSA's DPA.
'. FIRMR Bulletin C-5 (guidance) describes GSA's authority and
the review and response activities involved with an APR.
i Bulletin C-5 also describes an agency's recourse when GSA
disapproves an APR.
PHASE 3 - SOLICITATION PHASE
1 i
Step 14 - Prepare PRP
FIRMR 201-39 (po//cy) sets forth the rules for acquiring FIP
resources by contracting. Subpart 201-39.6 addresses
competition requirements and 201-39.10 addresses
specifications and standards.
FIRMR 201-20.3 (policy) prescribes the use of FIPS.
FIP Resource Acquisition Guide D-12
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Appendix D. Key References and Authorities by Step Step 14
NOTES FAR Part 4 (po//cy) requires an Independent Government
Cost Estimate (IGCE). The Office of Acquisition Management
(OAM) has issued a draft titled Guide for Preparing Independent
; . Government Cost Estimates, dated March 26,1993, which must
be used to do an IGCE.
FAR Part 6 (policy) prescribes competition requirements,
: including full and open competition and other than full and open
competition:
FAR Part 13 (policy) discusses small purchase procedures
and requirements.
i
FAR Part 37 (policy) describes Government policy and the
responsibilities of organizations when contracting for services.
i EPA Contracts Management Manual (policy), Chapter 2,
! provides guidance on preparing procurement requests and
related documents (including discussion of small purchases)
• and requires management approval before the Contracting
Officer (CO) processes the contract action. A copy of OMB
Circular A-120, "Use of Consulting Services," is provided in the
Contracts Management Manual (CMM).
EPA Delegations Manual (policy), Delegation 1-1OA,
! describes SIRMO approval authority limits.
EPA IRM Policy Manual (policy), Chapters 4, 6, and 8,
delegate OIRM responsibility for acquiring general purpose,
: non-application-specific software, and for approving
. system-oriented proprietary software. The manual also assigns
OAM responsibility for ensuring that all policy, standards, and
guidelines specified by OIRM are incorporated in request for
proposals (RFPs), contracts, and subcontracts and are specified
by the Office of Grants and Debarment in Interagency
'. Agreements, Cooperative Agreements, and Grants. It
establishes a comprehensive agencywide security program to
safeguard EPA information resources. It also sets forth EPA's
information security policy for manual and automated systems
and assigns individual and organizational responsibilities.
EPA Information Security Manual (policy).
FIP Resource Acquisition Guide D-13
-------
Appendix D. Key References and Authorities by Step Step 14
~" NOTES ' NDPD Operational Policies Manual (po//cy).
! i
; EPA TSCA Confidential Business Information Security
! Manual (po//cy) requires that a Request for Approval of
! Contractor Access to Toxic Substances Contract Act (TSCA)
Confidential-Business Information (CBI) (EPA Form 7740-17) be
included in the PRP when it is routed for approval.
i
! EPAAR 552.235 (policy) provides information pertaining to
: screening for claims of CBI, treatment of CBI, and data security
for the Federal Insecticide, Fungicide, and Rodenticide (FIFRA)
! and TSCA CBI.
^
i
! EPAAR 1515.6 (policy) provides information pertaining to -
i source selection.
i
EPAAR 1519 (policy) implements FAR Part 19, which
pertains to small business and small disadvantaged business
concerns.
t
, i
OARM Procurement Policy Notice 93-07 (policy) establishes
; policy and procedures for procurement actions under which EPA
: may furnish FIFRA and TSCA CBI.
OIRM Delegation 1-1OA (policy) includes a description of
; , OIRM's delegation of FIP resources procurement authority to
SIRMOs.
OMB Circular A-76 (policy) discusses requirements pertaining
to inherently Governmental functions.
i i
! OMB Circular A-94 (policy) provides guidelines for using
' discount rates when performing cost/benefit and economic
' analyses.
Supplement No. 2 to OMB Circular A-76 (guidance) is entitled
"A Guide For Writing and Administering Performance
Statements Of Work For Service Contracts." This guide may be
helpful when reviewing either agency-developed or
contractor-developed work statements. Another supplement to
Circular A-76 contains a "Cost Comparison Handbook."
FIP Resource Acquisition Guide 0-14
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Appendix D. Key References and Authorities by Step Step 15/16
NOTES The GSA Standard Solicitation Documents (guidance)
1 currently are available in electronic format and can be obtained
through the United States Government Printing Office (GPO);
stock number 022-003-01175-7. The following FIP resources
categories are addressed in the GSA Standard Solicitation
Documents series: FIP Software; FIP Maintenance; FIP
Equipment; and FIP Systems.
Step 15 - OIRM and OAM Review PRP
i
FIRMR 201-39.6 and 201-39.10 (po//cy) set forth the rules for
acquiring FIP resources by contracting.
i
: EPA IRM Policy Manual (po//cy), Chapters 1,4, and 6,
address IRM, software management, and ADPE resources
I ' management respectively, establishing the principles and
! requirements governing these FIP resources.
EPA Delegations Manual (policy), Delegations 1-10 and 1-
10A, assign responsibilities and authority for reviewing and
' • approving FIP resource acquisitions.
Supplement No. 2 to OMB Circular A-76 (guidance) is entitled
"A Guide For Writing and Administering Performance
i Statements of Work For Service Contracts." This guide may be
helpful when reviewing either agency-developed or
j : contractor-developed work statements.
Step 16 - Issue Solicitation
j FIRMR 201 -39 (policy/) sets forth the rules for acquiring FIP
! ! resources by contracting.
; I FAR Subpart 1.6 (po//cy) discusses the CO's authorities and
! responsibilities.
FAR Subpart 5.2 (po//cy) and EPAAR 1505 and EPA
Delegation 1 -1OA (policy) discuss publicizing contract actions.
i
FAR Parts 13 through 17 and 19 (policy) prescribe policy and
procedure for contracting methodology.
FIP Resource Acquisition Guide D-15
-------
Appendix D. Key References and Authorities by Step Step 17
NOTES EPA IRM Policy Manual (policy), Chapter 4, prescribes the
policies for acquiring software. Chapter 8 prescribes EPA's
information security policy.
PHASE 4 - SOURCE SELECTION PHASE
Step 17 - Evaluate Proposals and Award
Contract
FIRMR 201-39 (policy) sets forth FIRMR contracting policies
and procedures in a single part organized for consistency with
the FAR. This part contains only those contracting policies and
procedures that are unique to FIP resources.
FAR Subpart 15.6 (policy) prescribes policies and procedures
for selecting sources in competitive negotiated acquisition.
FAR Parts 13 through 17 and 39 (policy) prescribe policy and
procedure for contracting methodology.
EPAAR 1515.6 (policy) establishes EPA policies and
procedures for the source evaluation and selection processes.
EPAAR 1552.215 (policy) addresses the source evaluation
and selection process for negotiated procurements.
EPA Contracts Management Manual, Chapter 11, (policy)
provides guidance on safeguarding vendors' bids and
proposals.
GSA's Source Selection Procedures handbook (July 1987)
(guidance) includes guidance on staffing for selection, the
selection plan, evaluation, selection, and report and records
keeping.
GSA's Source Selection Procedures: Lessons Learned
(March 1991) (guidance) provides useful planning information
for source selection and evaluation reporting.
FIP Resource Acquisition Guide D-16
-------
Appendix D. Key References and Authorities by Step
Step 18/19
NOTES
PHASE 5 - CONTRACT
ADMINISTRATION PHASE
Step 18 - Track FIP Resource Costs and
Report Status
FIRMR 201-2 (po//cy) holds the DSO and designated agency
officials accountable for acquisitions acquired under a DPA.
FIRMR Bulletin C-5 (guidance), Attachment A, Instructions
For Preparing An Agency Procurement Request: Item six of the
APR requires the cost of the contract to be identified by type of
FIP resource for the contract life. These costs must "include all
anticipated optional quantities, resources, and periods."
GSA's A Guide For Contracting Officers' Technical
Representatives (guidance) provides useful information
regarding the roles and responsibilities of the PO.
Step 19 - Report DPA Status to GSA
DPAs granted by GSA prescribe reporting requirements
(policy.
FIRMR Subparts 201-22.202 and 201-22.203 (po//cy) discuss
GSA's Information Resources Procurement and Management
Review Program, which includes agency DPA procurements
FIP Resource Acquisition Guide D-17
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Appendix D. Key References and Authorities by Step
(This page intentionally left blank.)
FIP Resource Acquisition Guide D-18
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Appendix E. Determining FIRMR Applicability
Example 1
E. DETERMINING FIRMR APPLICABILITY
r~
NOTES
This Appendix provides guidance on determining when the
Federal Information Resources Management Regulation (FIRMR)
applies to an acquisition.
The two examples presented in this Appendix are intended to
describe the FIRMR applicability determination rationale. They
are based on real contract situations and discuss the
identification of Federal Information Processing (FIP) resources,
FIRMR applicability, and other Information Resources
Management (IRM) considerations.
Example 1
An office requires services to perform simulation modeling in
support of regulatory impact analysis. The office has determined
the services are best acquired through the procurement process.
The services needed include:
• Performing computer-based simulation model executions on
the Environmental Protection Agency's (EPA's) central
computing facility
• Statistical and graphical analysis and interpretation of
model results
• Quality control of all data used in the performance of the
contract
• Development and testing of algorithms to compute
contaminant concentrations (integration of these algorithms
in the software is tasked under another contract)
• Development of visualizations (movies)
• Analysis for development of a model evaluation protocol
and diagnostic model evaluation exercises using field data
FIP Resource Acquisition Guide E-1
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Appendix E. Determining FIRMR Applicability Example 1
NOTES Deliverables for this contract include:
• Tabular, statistical, and graphical analysis documents in
both hard copy and on disk in WordPerfect or ASCII format
• Briefing packages which must include text, graphics,
overhead transparencies, and/or slides
• Graphics and movies of simulation model outputs on video
media
• Copies of all scenario data outputs on magnetic tape or
floppy disk
Other Government-owned personal computer (PC) equipment
and software is available for contractor use on-site. EPA will
maintain the equipment under an existing maintenance contract.
Knowledge and experience requirements identified in this
contract include various physical science, engineering and
natural resource scientists with masters degrees and higher;
technical writers; and clerical personnel. All must have a
working knowledge of computers and the operation of related
software.
Discussion - To determine if and how the FIRMR applies to
the contract option, the originating office personnel responsible
for developing this solicitation should apply the following test
questions to the solicitation:
1. Does the solicitation require delivery of FIP resources for
use by EPA or any non-Federal agency users designated
by EPA?
"No" is the answer to this question. The purpose of the
solicitation is to provide scientific analysis reports, listings
and quality control of data used, and graphical depictions
of the model simulations.
2. Does a principle task of the solicitation depend directly on
the use of FIP resources?
FIP Resource Acquisition Guide E-2
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Appendix E. Determining FIRMR Applicability Example 2
NOTES "YES" is the answer to this question. The solicitation
requires the contractor to use the EPA central computing
; facilities to run model simulations. Also, other tasks are
: expected to require the use of computer equipment.
3. Do the requirements of the solicitation have the effect of
1 , substantially restricting the contractor's discretion in the
acquisition and management of FIP resources?
"No" is the answer to this question. The contractor is not
acquiring FIP resources and will either supply its own
equipment or will use government-owned equipment and
, software. Time share services on the EPA computer, if
needed, are provided by the originating office.
i Since no FIP resources are being acquired in this
! i procurement and "NO" is the answer to this third question,
further questions are unnecessary. The FIRMR's acquisition
requirements for new contracts do not apply to this contract
action and, therefore, a Requirements Analysis (RA), Analysis of
Alternatives (AA), and Implementation Plan (IP) are not
mandatory parts of the solicitation package.
Other IRM-Related Considerations - Because the use of
EPA's computer simulation model and central computing
, facilities is involved, the solicitation should identify any
requirements for the contractor to adhere to EPA operational
and security policies and plans when using the simulation
: model.
i
Identification of any requirements for training in the use of the
simulation model and adherence to Federal and EPA records
management policies and procedures is also required for
dealing with records associated with regulatory development.
Example 2
An office requires computer modeling and visualization
• software to support environmental regulatory impact analysis.
The system life and full life cycle costs were estimated and
analyzed to determine the cost-to-benefit ratio for the proposed
FIP Resource Acquisition Guide E-3
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Appendix E. Determining FIRMR Applicability
Example 2
NOTES
system and all alternative solutions. Based on the results, the
originating office determined that the most advantageous
alternative to fulfill this requirement is to contract for software
development. Management commitment and approval to
proceed was obtained and the EPAAR 1534 (Major Systems
Acquisition) requirements were reviewed for relevance and
followed where applicable.
The servicestfieeded include:
• Developing software based on EPA approved and
provided algorithms and requirements
• Optimizing software to run on the Agency's high
performance computer platform
• Developing visualization software
• Developing "tools" (e.g., PC or workstation software
"tools") for assessment of area specific effects of emission
control strategies on environmental conditions
• Managing and transferring all model input and output data
files between a number of computer systems and platforms
• Developing data sets for identified conditions for use in
model runs, providing data quality assurance (QA)
• Statistical and graphical analysis, interpretation of model
test results, and graphical displays of observed and
processed data
Government-owned computer equipment and software is
available for contractor use in Government facilities in this effort.
Discussion - To determine if and how the FIRMR applies to
the contract option, the originating office personnel responsible
for developing this solicitation should apply the following test
question to the solicitation:
FIP Resource Acquisition Guide E-4
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Appendix E. Determining FIRMR Applicability Example 2
NOTEST i 1. Does the solicitation require delivery of FIP resources for
i use by EPA or any non-Federal agency users designated by
EPA?
t
i "YES" is the answer to this question. This solicitation
1 ; supports regulatory development and analysis by developing
and/or acquiring software for use by EPA (i.e., FIP software
and support services). Whenever "YES" is the answer to this
, question, more questions on FIRMR applicability are
unnecessary. The FIRMR applies and an RA, AA, and IP
; must accompany the solicitation package to OIRM and OAM
and the originating office must compute the total FIP resource
cost over the life of the contract to determine if a delegation
i of procurement authority (DPA) is required.
FIP Resource Total Contract Cost Determination - The
, solicitation tasks primarily involve FIP resources (e.g., software
: development). They also include some non-FIP needs (e.g.,
; | scientific services). The originating office must estimate the
! ' total contract life cost for each category of FIP resource involved
< in this solicitation.
The first step is to determine which efforts are allocable as
FIP resources and which are not. Scientific services "tasks"
'j requiring only scientific expertise include:
| \ • Developing data sets for identified conditions for use in
> ' model runs, providing data QA
: i • Statistical and graphical analysis, interpretation of model
; test results, and graphical displays of observed and
' , processed data
!
i
I These "scientific" tasks determine valid data, interpret results,
and appropriately display the data and results for scientific
i review, evaluation, and verification. They and their associated
cost estimates are not allocable as FIP resources. Once these
non-FIP resources have been identified and quantified, the task
of quantifying the FIP resources of the acquisition become much
more straightforward.
FIP Resource Acquisition Guide E-5
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Appendix E. Determining FIRMR Applicability Example 2
NOTES DPA Determination - For purpose of determining if a DPA is
; required, the originating office must estimate the total contract
\ life costs for each category of FIP resources.
The contract's estimated total contract life is 3 years,
including all periods and options. Total estimated FIP resource
costs over the contract's life is $6 million. The cost estimate is
. broken down as follows:
FIP Hardware 0-
, FIP Software $ 250,000
FIP Services -0-
FIP Support services $5,400,000
FIP Supplies $ 50.000
Total FIP Resources $5,700,000
Total Other Than FIP Resources $ 300.000
Total Contract Costs >$6.000.000
Contract Life - 3 years.
The FIRMR does not apply to the "non-FIP" portion of the
solicitation. However, since FIP support services are
expected to exceed $2.5 million, a DPA from the General
Services Administration (GSA) is needed before this
solicitation may proceed.
Government-furnished computer equipment and software are
not part of the estimate because these items are government-
owned and their cost is not a factor in this solicitation.
Other IRM-Related Considerations - The use of EPA's
computer simulation model and central computing facilities is
involved; therefore, the solicitation should identify any
requirements for the contractor to adhere to EPA operational
and security policies and plans when using the simulation
model.
Furthermore, model development requires adherence to the
EPA's systems life cycle and software development policies,
procedures, and guidance. The originating office should also
FIP Resource Acquisition Guide E-6
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Appendix E. Determining FIRMR Applicability Example 2
NOTES ' review FIP and Agency standards to determine their relevance
to implementation of the model software.
FIP Resource Acquisition Guide E-7
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Appendix E. Determining FIRMR Applicability
(This page intentionally left blank.)
FIP Resource Acquisition Guide E-8
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Appendix F. Agency Procurement Request
Instructions
F. INSTRUCTIONS FOR PREPARING AN
AGENCY PROCUREMENT REQUEST
NOTES
The Program Office initiating the acquisition must use the
format prescribed in the Federal Information Resources
Management Regulation (FIRMR) Bulletin C-5, Attachment A,
when preparing an Agency Procurement Request (APR).
Attachment A is provided in its entirety herein (with minor
revisions in agency references) for the convenience of Program
Office staff. It is important to note that all ten (10) categories
identified in the instructions must be included in every APR
package.
Agency Information
Provide agency name, address, and location where the
Federal Information Processing (FIP) resources will be installed
or services will be performed. (Note: Be sure to discuss
expansion potential or other growth options possibly required
during the life of the contract.)
Provide the name, position title, organizational identity, and
telephone number of the senior program, technical, and
contracting officials assigned to the acquisition and a description
of the organizational structure to support these officials during the
acquisition.
When the dollar value of the acquisition is $25 million or
more, for each official identified above, provide the following
information:
• Experience in previous major FIP resource acquisitions.
• Responsibilities, scope of authority, and reporting structure
with respect to the acquisition.
• Whether assignment to the acquisition is full or part-time and,
if part-time, the nature of other responsibilities.
FIP Resource Acquisition Guide F-1
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Appendix F. Agency Procurement Request Instructions
NOTES Project Title and Description
Provide the project title and a brief but specific description of
the primary agency programs that the FIP resources will
support. (Note: Include a description of the relationship of the
project to agency missions and programs, a brief description of
the major information systems involved, and the project's
objectives.)
Current Support
Provide a brief but specific description of the current FIP
resources supporting these programs. (Note: The "Current
Environment" section of the Mission Needs Statement (MNS)
and the "current system" description in the Requirements
Analysis (RA) may be helpful in completing this section.)
FIP Resources To Be Acquired
Provide a brief but specific description of the FIP resources
to be acquired during the contract life. Include pertinent
information about the applications (e.g., automated data
processing [ADP], telecommunications) that will help the
General Services Administration (GSA) understand the require-
ments. This description should describe how changing require-
ments will be satisfied (e.g., resources required for system
expansion, anticipated augmentations, upgrades, and other
system modifications) during the contract life, if such
requirements will be included in the solicitation.
(Note: Establish clear requirements for the scope of the
program and procurement, but avoid being so specific that the
ability to subsequently modify the requirements will be hindered.
If applicable, briefly address the relationship of the required FIP
resources with any other associated acquisitions.)
Contracting Approach
Indicate whether or not the proposed contracting approach is
to satisfy a requirement using a specific make and model
FIP Resource Acquisition Guide F-2
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Appendix F. Agency Procurement Request Instructions
NOTES specification and whether compatibility-limited requirements will
; be used. (Note: The contracting approach should substantiate
that either the acquisition will maximize competition or that sole
. source is the agency's only option.)
Identify, by fiscal year and quarter, the planned milestones
for release of the solicitation and contract award. (Note:
' Provide dates for the key milestones such as Commerce Busi-
ness Daily (CBD) announcement, release of the Request for
: Comments and Request for Proposals (RFPs), request for Best
and Finals, and contract award.)
If the request involves a pilot or prototype, describe the
strategy for the follow-on implementation phase. (Note: Discuss
how competition will be ensured in the follow-on implementation
phase [e.g., how the agency will ensure that the pilot contractor
| does not have an unfair advantage for the follow-on].)
Indicate whether or not the acquisition plan (see the Federal
Acquisition Regulation [FAR] 7.104 (c)) contemplates
contracting under policies and procedures for:
• Full and open competition (see FAR Subpart 6.1)
• Full and open competition after exclusion of sources (see
i FAR Subpart 6.2)
• Other than full and open competition (see FIRMR Subpart
201-39.6 and FAR Subpart 6.3). In addition, provide the
applicable statutory contracting authority cited in FIRMR
; Subpart 201 -39.6 or FAR 6.302-1 through 6.302-7 permit-
\ ' ting the use of such procedures
i
Estimated Contract Life and Cost
i '
The estimated contract cost of the acquisition is to be
' identified by type of FIP resource for the contract life, and
' includes all anticipated optional quantities, resources, and
periods. Detailed cost breakdowns may be included when
necessary to describe clearly the estimated cost. The estimated
total contract cost (for all years) should correspond to the
planned contract life. The delegation of procurement authority
FIP Resource Acquisition Guide F-3
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Appendix F. Agency Procurement Request Instructions
NOTES (DPA) resulting from this submission (this APR) will be limited to
; , the contract cost and years set forth in it (this APR).
Estimated
FIP Resource Contract Cost
-FIP Equipment
! -FIP Software
-FIP Services
-FIP Support Services
-FIP-Related Supplies
TOTAL FIP Resources
TOTAL Other Than FIP Resources
' TOTAL Contract Cost
-Contract Life (Years)
(Note: Include optional quantities and periods in the APR
when a required DPA involves those options. Without optional
quantities and periods, the agency will not have sufficient
I ceilings to exercise those options. The solicitation must include
; all such options, proposals must include pricing for those
, options, and the awarded contract must reflect the options or
each option represents a sole source procurement and cannot
1 be exercised under that contract.)
Regulatory Compliance
Provide a statement to indicate that the agency reviewed
and complied (or will comply) with all applicable regulations; or
list the deviations from the regulations that apply to this request
for approval and provide an explanation for each deviation
request.
Provide the date of completion or most recent update of the
following documentation, or indicate not applicable (see FIRMR
Part 201-20):
FIP Resource Acquisition Guide F-4
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Appendix F. Agency Procurement Request Instructions
NOTES Documentation Date
' • Requirements analysis. mm/dd/yy
• Analysis of alternatives. "
; • Determination to support compatibility-
limited requirements. "
• Conversion study. "
; • Certified data to support a requirement
available from only one responsible source. "
• Certified data to support a requirement
using a specific make and model specification. "
• Description of planned actions to foster
! competition for subsequent acquisitions. "
; • Justification for more than one agency to
provide switching facilities or
services at building locations. "
• Exception to the use of Federal Telephone
: Service (FTS)/FTS-2000
mandatory network services. "
' • Exception to the use of GSA local
i • telecommunications service mandatory
! switching services.
(Note: If an item is listed as "not applicable," indicate the
reason why it is "not applicable.")
Agency Remarks
i Provide additional information concerning any of the above
. items or special conditions associated with this acquisition; e.g.,
i ! building construction/modification required by EPA. As
FIP Resource Acquisition Guide F-5
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Appendix F. Agency Procurement Request Instructions
NOTES applicable, request GSA multiyear contracting authority for
telecommunications resources.
a
(Note: Use the exact words that EPA would prefer GSA to
: use in the granted Delegation of Procurement Authority.)
i
Agency/GSA References
Provide references to related GSA delegations (including
previous GSA case numbers), meetings, telephone discussions,
etc.
Authorization
EPA-authorized signature, position title, organizational
identity, date.
(Note: The agency's Designated Senior Official (DSO) must
review and sign all APRs. At EPA this responsibility is
delegated to the Director, OIRM.)
FIP Resource Acquisition Guide F-6
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Appendix G. Contents of the Procurement Request Package Contents
G. CONTENTS OF THE PROCUREMENT
REQUEST PACKAGE
NOTES Tne following paragraphs describe the documents listed in the
Procurement Request Rationale Checklist and others that also
must be included in the Procurement Request Package (PRP), as
applicable. The Checklist itself must be included in the package,
as well. Whether some of the documents must be submitted or
not depends on the nature of the specific acquisition.
EPA FORM 1900-8. PROCUREMENT REQUEST/ORDER
Form 1900-8 is the standard Environmental Protection
Agency (EPA) form that describes the proposed procurement and
expenditures of the contract. Form 1900-8A may also be used if
additional information is provided. It is mandatory that Form
1900-8 be completed.
PROCUREMENT ABSTRACT
The Procurement Abstract is a summary of the statement of
work (SOW). It also synopsizes the nature of the procurement,
including the organization affected by the procurement, the
Federal Information Processing (FIP) resources involved,
schedule or estimated system life, and any other information the
Contracting Officer (CO) believes is necessary to include. The
abstract is used by the CO to notify vendors of the acquisition in
the Commerce Business Daily (CBD). The CBD is published by
the Department of Commerce to advertise acquisition opportuni-
ties and contract awards.
STATEMENT OR SCOPE OF WORK
The data gathering, analyses, and decisions made prior to
this point will strongly influence the SOW and solicitation (e.g.,
the results of the requirements analysis [RA] are incorporated into
the SOW). SOW development is a critical procurement process
because the SOW becomes a part of the contract and is
contractually binding on the contractor and the Government.
Furthermore, the SOW translates into cost and profit so every
FIP Resource Acquisition Guide G-1
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Appendix G. Contents of the Procurement Request Package Contents
NOTES wordin tne SOW is scrutinized and interpreted by offerers in an
effort to reduce cost and increase profit.
The following are general guidelines for writing a SOW:
• Describe what EPA will expect the vendor to accomplish,
including deliverables and delivery schedule, to satisfy
EPA's requirements.
• Describe work in clear, concise functional terms being
careful to describe "what" EPA wants and not "how" to
accomplish the tasks. The "how" is up to the vendor to
propose in the response to EPA's solicitation. The
offerers' methodology is evaluated by EPA to help
determine the best value for the Government. In some
cases, specific tools or methodologies are justified and
the SOW should clearly reflect these requirements;
however, in most cases an open solution allows the
offerers to provide more creative, innovative solutions in
their proposals.
• Logically and consistently format the subsections (e.g.,
hardware requirements in one section, software
requirements in a separate section).
• The SOW should promote and provide for full and open
competition and avoid even the appearance of vendor
bias.
The solicitation and cost proposal instructions will require
the offerers to itemize their cost proposals by individual FIP
resource category. The resultant contract must require the
winning contractor to itemize all invoices by individual FIP
resources category.
SOWs submitted to the Office of Information Resources
Management (01RM) and Office of Acquisition Management
(OAM) should follow the basic format prescribed below,
regardless of the contract type or FIP resources acquired:
• Section 1: Title - Provides the title of the program or
acquisition.
FIP Resource Acquisition Guide G-2
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Appendix G. Contents of the Procurement Request Package Contents
NOTES • Section 2: Period and Place of Performance - Identifies
: the dates the contract authorizes the contractor to work
' | and for which the Government is liable. This period is
; normally identified from date of contract award until the
end of the current contract. This section also identifies
the place(s) where the contractor will perform the work; if
! necessary, that performance may be at a Government
: facility. The contract should include adequate "option
i years."
:
• Section 3: Project Background Information - Describes
the circumstances leading up to the acquisition, other
, related contracts or activities, and the office(s) affected
\ by the acquisition.
/
; • Section 4: Purpose and Scope - Describes the purpose
, and expected outcome of the acquisition. This section
also describes what the acquisition encompasses
(scope). It provides boundaries for later determining
, whether or not a contract modification to add additional
tasks or requirements, or to change existing task
requirements, is within the scope of the contract. If a
modification request is "out of scope," that modification
E cannot go forward for CO signature. (Note: When the
original RA, Analysis of Alternatives (AA), and SOW are
i carefully researched and written, the need for contract
modifications is greatly reduced.
• Section 5: Tasks - Identifies all tasks, describes specific
components or requirements for completing the tasks;
and identifies deliverables associated with each task.
More specific information regarding deliverables is
provided in Sections 7 and 8. If FIP or EPA standards
are specified as a measure of performance, then the task
description must identify the standards the contractor
must meet to provide acceptable performance. Also, if
site visits can be predicted, then the sites and actual
' number of visits are listed in this section.
r>
> ' • Section 6: Description of Deliverables: Identifies every
deliverable and deliverable type (e.g., draft and final
documents, hardcopy and electronic copy, verbal
FIP Resource Acquisition Guide G-3
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Appendix G. Contents of the Procurement Request Package Contents
NOTES briefings, slide presentations, interim meetings, monthly
status reports, maintenance records and logs). For a
"services-type" contract, maintenance records, logs, or
account summaries may be all that is specified as a
deliverable, other than the actual service.
• Section 7: Acceptance Procedures for Deliverables -
Describes quantifiable criteria or service parameters for
determining that a deliverable is an acceptable
deliverable. Also describes the required format, condi-
tion, and quantities necessary to be acceptable. For
contracts intended to function through the use of Delivery
Orders or Work Assignments, this contract section will
specify the procedures for deliverables common to all
orders or assignments and note that further specificity will
be found in the SOWs for individual Delivery Orders or
Work Assignments.
• Section 8: Schedule of Tasks and Deliverables -
Describes the schedule for the contractor to submit draft
and final deliverables and for EPA to review and
comment or accept the deliverable.
• Section 9: Reporting Requirements - Describes any re-
ports not included in specific tasks under Section 7
above. This section describes verbal or written status-
type reports required, timeframes for delivery, and format
criteria. These types of reports may include a text
summary of the current month's activities, projections for
next month, problems encountered with actual or
proposed solutions, projected and actual expenditures,
an updated Gantt chart, etc. Distinguish between formal
reports versus informal status reports.
• Section 10: Labor Mix Requirements and Staff
Qualifications - Identifies the type(s) of professional and
non-professional personnel the client estimates are
required to perform the tasks. This section, along with
Section 12, is used to help evaluate the vendor's
proposed labor mix and estimate of staffing by task. This
section also lists the minimum qualifications for project
FIP Resource Acquisition Guide G-4
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Appendix G. Contents of the Procurement Request Package Contents
NOTES ~ personnel in terms of experience and/or education, and
j : whether one may be substituted for the other.
i
i ! • Section 11: Estimate of Staffing. By Task. In Labor
! i Hours - Lists the estimated hours and estimated cost for
; ' each labor category, by task.
i
; • • Section 12: Special Areas of Concern - Discusses areas
' ; that require special attention [e.g., security;
| ; Government-furnished information (GFI); sensitive
; information (either procurement or non-procurement);
program-specific information security requirements;
proprietary information (i.e., confidential business
| information (CBI)); contractor conduct; travel
requirements; contractor-provided quality assurance
(QA); EPA/contractor working relationships].
i
! Include the following additional information in, or as
, attachments to, the SOW:
I • Definitions, special terms, and acronyms that are used in
• the SOW and conform to existing Federal and EPA
! standards
i
• Applicable specifications, regulations, and documents
i • (e.g., EPA or industry IRM standards) or
• Technical documents and exhibits (e.g., floor plans, data
flow diagrams, models, and data entry forms)
: CONCISE TECHNICAL PROPOSAL INSTRUCTIONS
! Technical proposal instructions prescribe to offerers how to
organize, package, and submit the proposal. These instructions
will ultimately help the evaluators assess the proposal. One
advantage of having specific instructions is that evaluators can
quickly determine whether or not offerers provided all required
1 information.
FIP Resource Acquisition Guide G-5
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Appendix G. Contents of the Procurement Request Package Contents
NOTES COMPETITIVE TECHNICAL EVALUATION CRITERIA
Proposals are typically evaluated for their ability to meet the
solicitation's requirements and are scored on the basis of
technical and price merits. Technical evaluation criteria are
designed to maximize competition and minimize the complexity
of the evaluation and the selection decision. At the same time,
the criteria should reflect the relative importance of aspects of
the proposal (e.g., management, staffing, proposed technology).
Criteria should include essential, relevant, and measurable
technical requirements, since they provide the standards used
by the Technical Evaluation Panel (TEP) to determine whether
or not offerers' proposals meet the client's requirements from a
technical perspective.
Problems are likely to arise in the selection process if
technical evaluation criteria are not adequately planned and
consistent. Poorly written criteria often lead offerers to submit
information that is unnecessary. Also, once the evaluation
begins, the TEP may waste time debating exactly what the
evaluation criteria meant and/or resolving the disparity in the
proposals that result when a standard is poorly written or non-
existent.
JUSTIFICATION FOR OTHER THAN FULL AND OPEN
COMPETITION
Other than full and open competition refers to soliciting only
one or a limited number of sources and is governed by the
Federal Acquisition Regulation (FAR) Subpart 6.3. A
Justification for Other Than Full and Open Competition (JOFOC)
documents why a requirement must restrict competition.
Whenever other than full and open competition is being consid-
ered, consult with OAM. The CO must approve the JOFOC as
accurate and complete. If necessary, also consult the
appropriate the Senior Information Resources Management
Official (SIRMO) and the Office of Information Resources
Management (OIRM) for additional guidance. The JOFOC must
be signed at the client office's Division Director level.
Include as a critical part of the JOFOC, any supporting data
provided by the technical or requirements personnel that form
FIP Resource Acquisition Guide G-6
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Appendix G. Contents of the Procurement Request Package Contents
NOTES tne basis for the justification. The justification must contain
sufficient facts and rationale to justify using the statutory
exemption. Some of the important areas to address include:
• The statutory authority permitting a JOFOC (see FAR 6.3)
• The supplies and services required
• The proposed contractor's unique qualifications or the
nature of the acquisition that requires using the identified
statutory authority
• The efforts undertaken to ensure that offers were solicited
from as many sources as practicable (e.g., describe the
market survey performed or, if no market survey was
performed, state why not)
• Any other facts supporting the use of other than full and
open competition (e.g., list any sources that expressed an
interest in the acquisition)
An example of other than full and open competition is a
"make and model" justification that documents a situation where
only a specific manufacturer's make and model satisfies the
requirement. The JOFOC explains why no other types of
supplies or services will satisfy the requirement and the practical
factors that preclude using a less restrictive specification.
Another example of other than full and open competition is a
compatibility-limited justification where "compatibility-limited"
refers to a need for automated data processing equipment
(ADPE) or services compatible with existing ADPE or software.
Compatibility-limited requirements are invoked to alleviate the
need to convert existing ADPE, software, and related data.
Compatibility-limited requirements are to be used (1) only to
the extent necessary to satisfy the needs of the agency; (2)
when avoiding compatibility-limited requirements is not
advantageous to the Government; or (3) when a conversion
failure presents a risk to, and impact on, EPA's critical mission
needs which is so great that acquiring non-compatible resources
FIP Resource Acquisition Guide G-7
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Appendix G. Contents of the Procurement Request Package Contents
NOTES is unfeasible- When justifying compatibility-limited
requirements, the JOFOC must:
• Describe the impact on the user(s) if a compatible system
is not acquired (e.g., discontinuity of operations, or in-
ability to provide services)
• Describe the impact on EPA's mission if a compatible
system is not acquired
• Describe the economic and schedule impacts on EPA if a
compatible system is not acquired
DETERMINATION AND FINDINGS TO PROVIDE FULL AND
OPEN COMPETITION AFTER EXCLUSION OF SOURCE
The "Determination and Findings (D&F)" (FAR Subpart 1.7)
is a written approval by an authorized official that is required as
a prerequisite to (in this case) provide full and open competition
after exclusion of sources. According to FAR Subpart 6.2, the
agency may exclude a particular source from a contract action;
but the agency must meet the statutory requirements listed in
the FAR and submit a D&F that justifies and documents the
contract action.
JUSTIFICATION FOR ADVISORY AND ASSISTANCE
SERVICES
Justification for Advisory and Assistance Services is
discussed in Chapter 2, Paragraph 2.7 a, of the EPA Contracts
Management Manual (CMM). The Office of Management and
Budget (OMB) Circular A-120 addresses managing and
controlling contracts for advisory and assistance services. As
noted in Circular A-120, "ADP/Telecommunications may be
excluded if such functions and related services are controlled in
accordance with 41 CFR 201, the FIRMR." Also excluded from
the purview of the circular is "the day-to-day operation of
facilities (e.g., ADP operations)." A copy of Circular A-120 is
included in CMM Chapter 2, Attachment A. FAR Subpart 37.2,
states Government policy and the responsibilities of contracting
and requesting organizations regarding contracts for advisory
and assistance services.
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Appendix G. Contents of the Procurement Request Package Contents
NOTES As stated in the CMM, the justification must indicate that the
sen/ices to be performed will not:
• Unnecessarily duplicate any previously performed work
or services
• Be used in performing work of a policy decision making or
managerial nature
• Be used to bypass or undermine personnel ceilings, pay
limitations, or competitive employment procedures
• Be contracted for on a preferential basis to former
Government employees
• Be used specifically to aid in influencing or enacting
legislation
• Be used to obtain professional or technical advice that is
readily available within EPA or another Federal agency
A sample justification is provided in CMM Chapter 2,
Attachment B.
JUSTIFICATION OF NEED - GOVERNMENT-FURNISHED
PROPERTY
Normally, contractors are required to furnish all material for
performing Government contracts. However, FAR Part 45 states
that the agency may provide property required for contract
performance under certain circumstances.
Government-Furnished Property (GFP) consists of items
from Government inventories that are furnished to contractors
for contract performance. Contractor-acquired property (CAP)
means property acquired with contract funds, to which the
Government has title.
If applicable, the client must submit a written justification of
need to furnish GFP, or for the contractor to acquire property
(CAP) at the Government's expense, in accordance with CMM
Chapter 5. The information provided is reviewed by the CO and,
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Appendix G. Contents of the Procurement Request Package Contents
NOTES 'f approved, incorporated into the contract. After contract award,
the contractor is responsible and accountable for all GFP and
CAP in accordance with the requirements of the contract. This
includes Government property in the possession or control of a
subcontractor.
QUALITY ASSURANCE REVIEW FORM
Requirements pertaining to the QA Review Form are
discussed in CMM Chapter 2, Paragraph 2.5. The QA Review
Form is completed when the acquisition exceeds $25,000 and is
in one of the following object classifications:
Research and Development Contracts
Program Contracts
Occupational Health Monitoring
Occupational Health and Safety Other
Laboratory Supplies
Scientific and Technical Equipment
The CMM states that the PO is responsible for obtaining a
signed QA Review Form from the QA Officer responsible for
monitoring the client's acquisition program. This chapter of the
manual also requires the QA Officer or the alternate QA Officer
to serve on the TEP if the value of the procurement exceeds
$500,000.
RECOMMENDED SOURCES LIST
If applicable, the Recommended Sources List identifies
vendors or products that satisfy the SOW. A market survey
should identify available sources.
REPORTS DESCRIPTION
The Reports Description documents the reporting
requirements of the contract. Reports can include oral or written
reports, interim or monthly status reports, or various analytical
reports such as letters of findings, market surveys, analyses,
conversion studies, etc.
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Appendix G. Contents of the Procurement Request Package Contents
NOTES DISCUSSION OF CONTROLS FOR SENSITIVE
CONTRACTING
When contracting for services, or initiating a task order
under an existing contract, the client must be aware of, and plan
for, sensitive contracting areas. Certain activities, when
; performed by a contractor, may place the agency in a vulnerable
position if adequate management controls are not exercised!"
Chapter 2, Paragraph 2.7 b, of the CMM states that sensitive
contracting areas require justification and approval similar to
justifications for advisory and assistance services.
The following is a list of sensitive contracting areas from
Chapter 2, Attachment C, of the CMM:
• Budget preparation support
• Reorganization and planning support
• Support services used by agency personnel in developing
policy
t.
• Any support to the in-house evaluation of another
contractor's performance
• Involvement in strategic acquisition planning
• Support for improving contract management
• Providing specialized expertise in the source selection
process
• Providing specialized expertise in developing SOWs,
Delivery Orders, Work Assignments, and other
contract-related task orders
• Any support involving EPA policy or regulatory
interpretation
• Independently providing technical guidance concerning
EPA polices or regulations, on EPA's behalf, to outside
parties
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Appendix G. Contents of the Procurement Request Package Contents
NOTES The client must ensure that the proper security measures
are in place to protect sensitive information. Security measures
can be contractual in nature and/or deal more directly with
access to sensitive information.
As discussed in CMM Chapter 2, Paragraph 2.7 c and
Attachment D, the following contracting areas require the
establishment of special control measures:
• Situations where contractors share office space with EPA
employees
• Support in preparing responses to Freedom of
Information Act requests
• Any situation where a contractor has access to
confidential business information and/or any other
sensitive information
• Any situation where it can be assumed that the contractor
is EPA, without specifically identifying itself as a
contractor
When a procurement involves any of these areas, the
Checklist requires that the PRP contain a discussion of how the
appropriate controls will be applied. Chapter 2, Attachment E, of
the CMM provides a sample of this discussion.
The Federal Information Resources Management Regulation
(FIRMR) and the Computer Security Act require security
requirements to be identified and for the agency to provide
security of resources, including protecting information about
individuals.
The EPA Information Security Manual provides overall
guidance to agency managers and staff for implementing
security procedures. Chapter 4 of the Information Security
Manual provides information for determining the need for
additional controls, if it appears that existing contractual or
system controls are not adequate.
FIP Resource Acquisition Guide G-12
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Appendix G. Contents of the Procurement Request Package Contents
NOTES The Office of Administration and Resources Management
(OARM) Procurement Policy Notice 93-07 establishes policy
and procedures for procurement actions under which EPA may
furnish the Federal Insecticide, Fungicide, and Rodenticide
(FIFRA) and the Toxic Substances Control Act (TSCA) CBI.
Some sensitive contracting areas are those in which,
generally, only agency personnel should be involved. For
various reasons (e.g., lack of resources or a need for
specialized expertise) it may be advantageous to the
Government to use a contractor. However, as discussed in
CMM Chapter 2, Paragraph 2.7 d, certain activities are
considered "inherently Governmental" in nature and, therefore,
are not permitted to be performed by contractors. A list of these
prohibited contracting activities is contained in CMM Chapter 2,
Attachment F. (Also, see OMB Circular A-76, Performance of
Commercial Activities, for further information on contracting
responsibilities regarding inherently Governmental functions.)
DISCUSSION OF HOW PROCUREMENT FITS INTO OVERALL
CONTRACTING STRATEGY (IF REQUIRED)
For procurements containing a FIP resource(s) component
that is part of a larger contract, the client must include in the
PRP a description of how the FIP component interacts with the
overall contract and contracting strategy. Also, for both advisory
and assistance and sensitive contracting areas, the client must
include a description of how the FIP component interacts with
the overall contracting strategy. Chapter 2, Paragraph 2.7 e, of
the CMM discusses this requirement.
INDEPENDENT GOVERNMENT COST ESTIMATE
In accordance with FAR Par 4, the contract file must contain
an Independent Government Cost Estimate (IGCE). The IGCE
must identify each FIP resource and include resource usage
estimates along with the associated unit cost for each FIP
resource category item. Examples of resource usage include
skill category, labor hours by skill category, machine time,
software leases, and materials. A thorough estimate should (1)
provide the rationale used in deriving the resource estimates; (2)
indicate the source of the cost data used; and (3) explain any
FIP Resource Acquisition Guide G-13
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Appendix G. Contents of the Procurement Request Package Contents
NOTES assumptions or constraints affecting the estimate. At this point,
the client should once again reconcile the proposed acquisition
with the client organization's budget. In preparing an IGCE, the
OAM draft Guide for Preparing Independent Government Cost
Estimates, dated March 26,1993, must be used.
DESIGNATION AND APPOINTMENT OF PROJECT
OFFICER/WORK ASSIGNMENT MANAGER/DELIVERY
ORDER OFFICER (EPA Form 1900-65)
This form is used to designate the PO for a contract and
Delivery Order Project Officers (DOPOs) or Work Assignment
Managers (WAMs), as required by the particular type of
contract. This form informs the CO of the client's proposed
designee(s). The CO, in turn, countersigns the form
legitimatizing the designation(s).
TECHNICAL EVALUATION PANEL MEMBERS LISTING
This document identifies the members of the TEP. The
information required for this document is taken from the acquisi-
tion plan, which is normally completed by this time.
PROCUREMENT INTEGRITY CERTIFICATIONS FOR
PROCUREMENT OFFICIALS
Procurement officials are required to sign a non-disclosure
form, stating that the official understands and will abide by
Federal acquisition regulations. Officials may also be requested
to sign a conflict-of-interest statement.
REQUEST FOR APPROVAL OF CONTRACTOR ACCESS TO
TSCA CBI (EPA FORM 7740-17)
EPA's TSCA CBI Security Manual requires that a Request
for Approval of Contractor Access to TSCA CBI (EPA Form
7740-17) be included in the PRP when it is routed for approval.
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Appendix G. Contents of the Procurement Request Package
Contents
NOTES
ADP APPROVAL MEMORANDUM
This document acknowledges the review and approval of
the client's plans to procure ADPE or other FIP resources. The
memorandum is developed by OIRM.
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Appendix G. Contents of the Procurement Request Package
(This page is intentionally left blank.)
FIP Resource Acquisition Guide G-16
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Appendix H. Acquisition of FIP Resources by Small Purchase
Guidance
H. ACQUISITION OF FIP RESOURCES BY
SMALL PURCHASE
NOTES
Acquisition through the use of small purchase procedures is
intended to offer requisitioners a less burdensome means of
acquiring goods and services. The current small purchase
threshold is $25,000, as set forth in the Federal Acquisition
Regulation (FAR) Part 13. Before using small purchase
procedures, the client should determine whether there is an
existing Environmental Protection Agency (EPA) contract that
could satisfy the requirement.
FAR Subpart 5.2 and Chapter 2 of the EPA Contracts
Management Manual (CMM) provide additional guidance on small
purchases.
A purchase request for a small purchase action results in the
issuance of a purchase order. A purchase order is a firm fixed-
price instrument. Therefore, precise product and/or service
descriptions are needed.
EPA currently has no standard checklist for small purchase
requests, but the list below will cover most small purchase
actions. Some of these items (such as the Government-
Furnished Property [GFP] Justification) are required only if
applicable.
• EPA Form 1900-8, Procurement Request/Order
• Statement of Work (SOW) or Product Description
• Justification for Other Than Full and Open Competition
(JOFOC)
• Sole Source Justification (If < $2,500)
• Justification for Advisory and Assistance Services
FIP Resource Acquisition Guide H-1
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Appendix H. Acquisition of FIP Resources by Small Purchase
Guidance
NOTES
• Justification of Need - Government-Furnished Property
(GFP)
• Recommended Sources List
• Reports Description
• Discussion of Controls for Sensitive Contracting
• Independent Government Cost Estimate (IGCE)
• ADP Approval Memorandum
• Any program-specific information security forms that
apply
The client may acquire FIP resources through the use of a
Government bankcard. However, the client is cautioned to
follow the guidance issued for that program. (Of note is the
prohibition against the purchase of nonexpendable, accountable
personal property over $1,000 in cost.
Reference and Authority Documents
• FAR Part 13(po//cy).
• EPA Small Purchases, A Guide for Program Offices
(guidance).
• Cardholder Instructions, The U.S. Government Credit
Card (po//cy).
• EPA Bankcard Training and Call Ordering Officer Course
Manual (guidance).
• EPA Contracts Management Manual, Chapter 2 (po//cy).
• Office of Information Resources Management (OIRM)
Delegation 1-1OA
FIP Resource Acquisition Guide H-2
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Appendix I. Points of Contact
POCs
I. POINTS OF CONTACT
NOTES
OFFICE OF ACQUISITION
MANAGEMENT (OAM)
Contracts Management Division
Cincinnati, Ohio 45268
(513)366-2002
'^Contracts Management Division, MD-33
Research Triangle Park (RTF), North Carolina 27711
(919)541-3045
Headquarters Procurement Operations Division, 3803F
Fairchild Building
Washington, DC 20003
(202) 260-6035
OFFICE OF INFORMATION RESOURCES
MANAGEMENT (OIRM)
Office of the Director, 3401
401 M. Street S.W.
Washington, DC 20460
(202) 260-4465
Management and Evaluation Staff, 3401
401 M. Street S.W.
Washington, DC 20460
(202) 260-2381
Oversight and Compliance Support Staff, 3401
401 M. Street S.W.
Washington, DC 20460
(202) 260-2381
FIP Resource Acquisition Guide 1-1
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Appendix I Points-of -Contact
POCs
NOTES
OFFICE OF SMALL AND
DISADVANTAGED BUSINESS
UTILIZATION (OSDBU)
Office of Small and Disadvantaged Business Utilization,
1230C
401 M. Street S.W.
Washington, DC 20460
(703) 305-7305
FIP Resource Acquisition Guide 1-2
OUS GOVERNMENT PRINTING OFFICE 1991-615-791-81175
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SUGGESTION FORM
Please use this suggestion form to offer comments, suggest
changes or identify needed corrections. It would be helpful if
the Oversight and Compliance Support Staff were able to discuss
your suggestions with you; however, if you prefer,you need not
identify yourself.
OPTIONAL: Name:
Telephone:
Please submit to: Irv Weiss
Oversight and Compliance Support Staff
(3401)
(202) 260-2381
-------
HOW TO RECEIVE UPDATES TO THE GUIDE
As the FIRMR, FAR, and Agency IRM policy change, we plan to
update this guide. In order to receive updates to this guide, the
Information below must be provided to OCSS. Print your name,
organization, mall code and telephone number In the spaces'noted
below. This form will be retained by the Oversight and Compliance
Support Staff expressly for this purpose.
NAME:
ORGANIZATION:
MAIL CODE:
TELEPHONE:
Please submit to: Irv Weiss
Oversight and Compliance Support Staff
(3401)
(202) 260-9388
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