The next steps in the Revolutionary FAR Overhaul, continued…

This column was originally published on Roger Waldron’s blog at The Coalition for Common Sense in Government Procurement and was republished here with permission from the author.

Last month, the FAR & Beyond blog highlighted the importance of the formal rulemaking process in cementing the regulatory streamlining accomplished during Phase I of the Revolutionary Federal Acquisition Regulation Overhaul (RFO). Robust, consistent, and transparent public rulemaking will ensure a sound, fulsome consideration of the regulatory changes. Given the significant changes across the entire FAR, it is critical that the public be given sufficient opportunity to examine, analyze, and provide comment on the changes. For example, key stakeholders should have the opportunity to share their experiences operating under the RFO deviations. Are there lessons learned that can further enhance and/or streamline the regulations? Are there additional opportunities to reduce barriers to entry for commercial firms? Are there any unintended consequences where refinements to the regulations can be made to achieve the RFO’s streamlining goals? A positive, engaged rulemaking process is a major step in ensuring the success of the RFO.

The FAR, as transformed by the RFO, is the framework by which the government and industry transact business in support of the federal mission. As such, it is fundamental to the RFO’s success that an engaged, empowered acquisition workforce leverages the new flexibilities to deliver timely, best value mission support for customer agencies. The acquisition workforce includes those in the government and the private sector. It will be important that the acquisition workforce understands the RFO’s underlying philosophy and strategic goals. In addition, providing guidance, context and training on the RFO’s flexibilities, nuances and discretion-based decision making is critical. Contracting officers must be willing to embrace and exercise the discretion the RFO has empowered them with to make sound, best-value business decisions.

To this end, the FAR Council has developed resource materials to support the acquisition workforce in understanding and applying the RFO. Acquisition.gov includes a host of resources for the acquisition workforce. The “FAR Companion” is a consolidated guide that includes practitioner tips and how-to procedures for the acquisition workforce. It also provides helpful context on the goals of the RFO. There are also RFO Practitioner Albums that provide context on the changes in each FAR Part and guidance on implementation/application of the new rules. For example, the Practitioner’s Album for the various new FAR Parts include “Smart Accelerators” that provide guidance on acquisition techniques and practices.

These resources are a positive step in developing the intellectual and practical guidance supporting the RFO. The acquisition community looks forward to the RFO’s “Buying Guides” as the next step. Finally, the Federal Acquisition Institute and the Defense Acquisition University will play leading roles in ensuring the acquisition workforce has the resources to embrace and execute the RFO.

The guidance materials developed for the acquisition workforce in support of the RFO are the building blocks for operational success. Management accountability to the RFO’s goals will also be crucial. Accountability will ensure consistency in application of the new business rules. Inconsistency drives risk, and increased risk translates into higher prices and costs for both contractor and customer. It will take a significant effort across all management levels of the acquisition workforce to embrace the RFO.