PSC’s 2013 Policy

Priorities

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PS C' S 201 3 T O P PO L ICY PRI ORIT IES

The federal professional services industry is a key strategic partner to the federal government and has a longstanding record of providing critical support to all federal agencies. Through partnerships with the private sector, the federal government is able to tap the best of the private sector's innovation, expertise and technology, as well as its highly qualified and nimble workforce. At the same time, the government’s private-sector partners serve as vital cogs in the nation’s economic engine by being leaders in job creation, research and development, and skilled workforce development. This partnership greatly benefits the government, the taxpayer and our national economy.

PSC's policy agenda is focused on sustaining and enhancing that critical partnership. Our agenda seeks to strike the right balance of appropriate and necessary responsibilities and oversight associated with the public trust; to provide the government access to the best the private sector has to offer; and to enable the firms supporting the government to continue to grow, innovate and deliver. PSC's 2013 Policy Priorities are outlined below and will be continually refined as circumstances warrant.

I. Provide Budget Stability

An unclear budget picture complicates the ability of the government and industry to effectively plan for changing priorities. Furthermore, nonstrategic mandates or arbitrary cuts to reduce spending hamstring government agencies and jeopardize government and industry short-term and long-term investments. While budget austerity is unavoidable, the lack of predictability and consistency of federal budgets is much more detrimental than clearly articulated funding reductions. To inject certainty into the federal budget process, PSC will advocate for the government to:

Avoid across-the-board cuts, such as those that would be required by sequestration, and provide federal agencies with sufficient flexibility and time to make strategic decisions about missions and investments.

Evaluate initiatives focused on services contracting reductions to determine whether such approaches are tactically sound, and to explore balanced alternatives.

Restore “regular order” to the appropriations process to provide consistent, predictable and timely funding for agency and contractor planning.

Ensure agency initiatives do not sacrifice long-term savings or access to innovation by focusing exclusively on short-term cost savings.

II. Achieve Acquisition Excellence

Achieving acquisition excellence will be a topic of considerable attention in the administration and the 113th Congress. Efforts will include IT acquisition reform, services contracting reform, and increased reliance on strategic sourcing. Ongoing agency-specific exercises, such as DoD’s Better Buying Power 2.0 initiative, will also drive additional reforms. To ensure that industry has a voice in these deliberations, PSC will advocate for the government to:

Avoid legislation or regulation that limits agencies’ ability to procure commercial services in a streamlined manner.

Align acquisition processes and techniques more closely to the government’s services and information technology requirements.

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Constrain the expansion of non-competitive program execution strategies that lack transparency and accountability, including the inappropriate use of Federally Funded Research and Development Centers (FFRDCs), University Affiliated Research Centers (UARCs), federally sponsored labs, and the increasing preference for grants over contracts.

Monitor the frequency of “lowest price technically acceptable” (LPTA) evaluation strategies and reduce the misuse of LPTA in circumstances that are better suited for reasonable and tailored cost-technical tradeoff approaches.

Align contract management strategies with contract type, e.g. avoid managing fixed price contracts as though they are cost-type contracts.

Focus strategic sourcing initiatives on commodities that require little or no customization.

Balance legitimate cybersecurity, information protection, software development, or supply chain security needs with equally legitimate standards and liability protection for companies.

III. Mission-Focused Human Capital/Workforce

Policymakers must adopt strategies that allow the government to manage its total workforce resources, including military personnel, civilian employees, and contractors. Too often, reforms seek to favor one sector over another, forcing agencies to make nonstrategic workforce decisions. Where critical skills and core competencies should be performed only by federal employees, effective training must be a top priority. To encourage sound human capital policies, PSC will advocate for the government to:

Develop and use cost comparison models that enable accurate cost comparisons between public- and private-sector performance.

Protect industry’s ability to compete for appropriate work .

Eliminate unreasonable agency-by-agency caps on contractor labor and overhead rates.

Retain a contractor compensation allowability mechanism that preserves contractors’ ability to compete with the commercial market for a highly talented workforce.

Prevent government from inappropriately interfering with contractor personnel and hiring decisions.

Ensure acquisition workforce training develops an understanding of business risk and critical thinking, in lieu of “check the box” processes.

Enhance the speed and scope of federal acquisition workforce training/development, with a particular focus on the acquisition of services.

Develop policies and incentives that foster longevity and expertise within the ranks of the federal acquisition workforce.

Encourage greater communication between the federal acquisition workforce and the private sector by reiterating recent OFPP “mythbusters” guidance and developing new collaboration initiatives.

IV. Balance Oversight and Regulatory Reviews

Government contracting is, appropriately and by its nature, significantly regulated. However, regulatory and oversight requirements on government contractors continue to grow, often with little or no analysis of their impacts or their efficacy. To achieve effective oversight, PSC will advocate for the government to:

Require periodic reviews of agency regulations to ensure such regulations are still warranted.

Reform federal suspension and debarment and past performance reporting procedures to maintain contractors’ appropriate due process protections while effectively protecting the government’s interests.

Avoid duplicative contractor data reporting requirements for information that is already available to the federal government or that places significant cost burdens on contractors with little or no government benefit in return.

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Continue to refine Defense Contract Audit Agency (DCAA), Defense Contract Management Agency (DCMA), Department of Labor and other audit and investigation practices to improve timeliness and clarity and foster a more collaborative relationship between government and industry.

Better focus the work of international development-focused Inspectors General (IGs) and audit agencies (e.g. USAID-IG, State Dept.-IG, DoD-IG, SIGIR and SIGAR) on high risk activities and ensure greater coordination to avoid duplication and excessive compliance costs.

V. Preserve and Enhance the Services Industrial Base

It is in the government’s best interest to adopt policies that enable robust opportunities for small companies to thrive while ensuring that companies other than small businesses have the opportunity to grow and succeed. To help preserve and enhance the services industrial base, PSC will advocate for the government to:

Enhance competition that encourages and rewards innovation and efficiency.

Structure small business contracting opportunities in a manner that fosters successful outcomes and business longevity after contract completion, i.e. ensure that only contracts of the right size and scope are set aside for small business competition.

Collect and report all dollars awarded to small business concerns at all tiers.

Reform small business size standards to more appropriately address the realities of the federal marketplace and provide real opportunities for entrepreneurship.

Evaluate contracting policies’ effect on mid-tier firms.

February 5, 2013