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NPS has utilized several contracting activities in order to meet the emerging requirements to support our programs. The major Non-DoD contracting vehicles used by NPS include the General Services Administration (GSA), the Department of the Interior via the Open Market Corridor (OMC), and the Department of Veteran’s Affairs (VA).
Recent guidance from DoN (PDF) has restricted the use of non-DoD contracting vehicles. The recent DON guidance is in addition to Financial Management Regulations guidance requiring review when funds are sent outside of DoD.
All contracting actions using a non-DoD contracting office must now be reviewed. There are two levels of review.
1) All requests for use of a Non-DoD contracting vehicle must be reviewed regardless of dollar amount to assure it is in the best interest of the government to use the non-DoD vehicle. The review is called an Economy Act Determination and Finding. NPS cannot sign the Economy Act D&F. The Economy Act D&F must be signed by NAVSUP and be endorsed by FISC-San Diego. NPS is seeking relief on this guidance.
2) All requests for use of a Non-DoD contracting vehicle over $100k must also be reviewed by a committee consisting of Legal, Financial and Contracting Office Representatives. Legal and Financial Representatives reside at NPS; the Contracting Office representative resides at FISC-SD.
3) GSA is exempt from the Economy Act D&F, but orders over $100k will still require the Legal/Financial/Contracting Office review. IT orders will also require NPS CIO review.
The following guidance is applicable:
FISC San Diego: FISC will be the primary servicing activity for all contract requests. FISC is working diligently with NPS to assure they can meet our requirements.
OMC: Until further notice, we will not be utilizing the OMC vehicle for new contracting actions. Existing actions will continue. Modifications will be processed for incremental funding on current tasks.
Modifications which increase the level of effort (add hours) to current tasks will be processed. Modifications which add "new tasks" will not be processed. These new tasks will be forwarded to FISC for action. Economy Act D&Fs will be required for all current OMC contracts with open actions, i.e. incremental funded tasks and tasks requiring modifications.
GSA: GSA may be used for orders under $100k. GSA orders in excess of $100k will require review (Legal/Financial/FISC). The review must be completed prior to the order being placed with GSA. Currently NPS is utilizing GSA for IT procurement and services only. We are exploring the use of other GSA contracts for supplying technical services. A “certification” is required on all GSA task orders (PDF).
VA: The VA is no longer accepting new requirements. Current contracts will be completed.
Please understand that the timelines for awarding a contract that you have experienced in the past may not be possible.
Your patience is greatly appreciated. NPS is working to resolve the remaining issues and we will provide additional guidance.
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