R 181750Z APR 12 ALCOAST 178/12 COMDTNOTE 7403 SUBJ: ASSESSMENT OF CONTRACTOR SUPPORT SERVICES A. DHS OFFICE OF CHIEF PROCUREMENT OFFICER (OCPO) DIRECTOR, POLICY AND ACQUISITION WORKFORCE, ACQ. ALERT 11-30 DTD 30SEPT11 B. DHS OFFICE OF CHIEF PROCUREMENT OFFICER (OCPO) DIRECTOR, POLICY AND ACQUISITION WORKFORCE, AMEND 1 ACQ. ALERT 11-30 DTD 23DEC11 1. ON 30SEPT11, DHS OCPO ISSUED REF A REQUIRING NEW PROCESSES AND ADDITIONAL REVIEW ELEMENTS RELATED TO ASSESSING CONTRACTOR SUPPORT SERVICES REQUIREMENTS, EMPHASIZING THE REVIEW RESPONSIBILITY OF REQUIRING ACTIVITIES. THIS GUIDANCE APPLIES TO ALL NEW REQUIREMENTS FOR SERVICES OVER THE SIMPLIFIED ACQUISITION THRESHOLD (SAT)(I.E.150K) AND REQUIRES AN ASSESSMENT AND WRITTEN DETERMINATIONS BY THE REQUIRING ACTIVITY THAT NO INHERENTLY GOVERNMENTAL (IG), CLOSELY ASSOCIATED, CRITICAL FUNCTIONS OR PERSONAL SERVICES ARE INCLUDED IN THE STATEMENT OF WORK (SOW) AND THAT SPECIAL CONSIDERATION TO HIRING FEDERAL EMPLOYEES HAS BEEN ADDRESSED. THESE REQUIREMENTS WERE PREVIOUSLY ADDRESSED IN COCO ALERT 12-08 DATED 21OCT11. 2. REF B WAS ISSUED ON 23DEC11 AS AMENDMENT 1 TO REF A. THIS AMENDMENT EXPANDS THE DEFINITION OF NEW WORK TO INCLUDE ASSISTED ACQUISITIONS (IAAS), PROVIDES FOR CONTINUOUS ASSESSMENT AFTER CONTRACT AWARD, REQUIRES ADDITIONAL CODING IN THE DESCRIPTION FIELD WITHIN THE FEDERAL PROCUREMENT DATA SYSTEM - NEXT GENERATION (FPDS-NG) RECORD FOR SUCH REQUIREMENTS AND LEGAL CONCURRENCE FOR ALL ACTIONS ABOVE THE SAT PRIOR TO SUBMISSION OF THE SOW AND PROCUREMENT REQUEST TO THE CONTRACTING OFFICER (KO). THE AMENDMENT ALSO INCLUDES THE DHS GUIDE FOR PERFORMANCE OF INHERENTLY GOVERNMENTAL AND CRITICAL FUNCTIONS THAT PROVIDES INSTRUCTION FOR COMPLETING DETERMINATION TEMPLATES AND OUTLINES REQUIREMENTS FOR USE OF THE BALANCED WORKFORCE STRATEGY (BWS) SOURCING DECISION TOOL IF THE REQUIREMENT IS ABOVE THE SAT AND IS INCLUDED ON A LIST OF 17 SPECIAL INTEREST FUNCTIONS (SIF) PRODUCT SERVICE CODES (PSC). FOR SERVICES ACQUISITIONS ABOVE THE SAT, THE REQUIRING ACTIVITY SHALL COMPLETE THE DETERMINATION TEMPLATES/CHECKLISTS (ATTACHMENTS A-D) IN THE DHS GUIDE. ADDITIONALLY, FOR BWS APPLICABLE SOURCING DECISIONS, THE REQUIRING ACTIVITY SHALL COMPLETE ATTACHMENTS A-D AND THE COST ESTIMATING AND COMPARISION WORKSHEET (ATTACHMENT E) FROM THE GUIDE. THESE REQUIREMENTS WERE PREVIOUSLY ADDRESSED IN COCO ALERT 12-28 DATED 24FEB12. COCO ALERTS 12-08 AND 12-28 AND ASSOCIATED REFS A AND B ABOVE CAN BE ACCESSED VIA THE FOLLOWING LINK: HTTPS://CGPORTAL.USCG.MIL/CTL/1EDCHSE 3. THE COAST GUARD (CG) SHALL COMPLY WITH THE STATUTORY REQUIREMENTS PROHIBITING THE AWARD OF SERVICE CONTRACTS FOR WORK THAT IS INHERENTLY GOVERNMENTAL AND WILL TAKE APPROPRIATE STEPS TO ENSURE THAT SPECIAL CONSIDERATION IS GIVEN BEFORE THE AWARD OF CONTRACTS FOR FUNCTIONS CLOSELY ASSOCIATED WITH THE PERFORMANCE OF AN INHERENTLY GOVERNMENTAL FUNCTION. ALL CONTRACTING AND PROGRAM MANAGEMENT PERSONNEL ARE REQUIRED TO REVIEW THE DHS AA 11-30 (REF. COCO ALERT 12-28, ATTACHMENT 1 AND ASSOCIATED CRITICAL FUNCTIONS GUIDE, ATTACHMENT 2). THESE DOCUMENTS ALONG WITH OTHER INFORMATION AND TRAINING MATERIALS CAN BE FOUND AT: HTTPS://CGPORTAL.USCG.MIL/CTL/1EDCHSE IN ORDER TO ACHIEVE COMPLIANCE WITH STATUTES WHILE MINIMIZING THE BURDEN ON THE REQUIREMENTS COMMUNITY, CG WILL BE FOLLOWING A MODIFIED/PHASED APPROACH TO IMPLEMENTATION AS INDICATED IN PARAGRAPHS 4 AND 5 BELOW. 4. CG IMPLEMENTATION RAISES THE THRESHOLD FOR LEGAL REVIEW OF THE PROCUREMENT REQUEST PACKAGE SUBMISSIONS TO SERVICES GREATER THAN 500K, AND THE TIMING OF THE LEGAL REVIEW WILL OCCUR DURING THE COURSE OF THE PROCUREMENT PROCESS AND BE INITIATED BY THE KO. 5. INITIAL CG IMPLEMENTATION RAISES THE THRESHOLD TO 500K OR ABOVE FOR SERVICES REQUIREMENTS SUBJECT TO BWS ANALYSIS AND ON-LINE TOOL BASED UPON THE SPECIAL INTEREST FUNCTIONS (SIF) PRODUCT SERVICES CODES (PSCS). IN ADDITION, CG WILL UTILIZE THE SPC TABLE VICE THE DHS MODULAR COST SPREADSHEET IN CONDUCTING COST COMPARISION ANALYSIS. 6. TO PROVIDE ADEQUATE TIME TO TRAIN IMPACTED PARTIES ON THESE NEW TOOLS, ON AN INTERIM BASIS FOR PROCUREMENT REQUESTS GREATER THAN THE MICRO-PURCHASE THRESHOLD (I.E.3K) BUT LESS THAN THE SAT, REQUIRING ACTIVITIES SHALL PROVIDE AN AFFIRMATIVE STATEMENT IN THE DESCRIPTION BLOCK THAT STATES NO IG FUNCTION IS INCLUDED IN THE SOW AND SPECIAL CONSIDERATION TO HIRING FEDERAL EMPLOYEES HAS BEEN ADDRESSED. FOR PROCUREMENT REQUESTS ABOVE THE SAT, REQUIRING ACTIVITIES SHALL COMPLETE THE DETERMINATION TEMPLATES. 7. FUTURE TRAINING OPPORTUNITIES WILL BE POSTED ON THE HQS SPECIAL NOTICES BOARD AND COMDT (CG-913) PORTAL. 8. FOR QUESTIONS CONCERNING THE USE OF SPC TABLES FOR BWS COST COMPARISONS, CONTACT STEVE PHIFER, COMDT (CG-832), AT STEVEN.K.PHIFER (AT)USCG.MIL OR (202) 372-3573. FOR QUESTIONS REGARDING DHS BWS GUIDANCE, CONTACT DAVID MCLEISH, COMDT (CG-12A), AT DAVID.B.MCLEISH(AT)USCG.MIL OR 202 475-5230. QUESTIONS REGARDING CONTRACTING OFFICER RESPONSIBILITIES, CONTACT MARK HOPKINS, COMDT (CG-9132), AT MARK.L.HOPKINS(AT)USCG.MIL OR (202) 475-3092. 9. RELEASED BY MS. CLAIRE M. GRADY, SENIOR PROCUREMENT EXECUTIVE AND HEAD OF CONTRACTING ACTIVITY 10. INTERNET RELEASE AUTHORIZED.