In a memorandum dated June 15, 2017, Office of Management & Budget (OMB) Director Mick Mulvaney continues to follow through on the administration’s pledge to eliminate red tape and reduce unnecessary, duplicative, and redundant reporting requirements for federal agencies.
The M-17-26 memo pauses, modifies, or altogether eliminates fifty requirements. Which ones have a direct impact on the day-to-day operations of federal procurement professionals? We dove into the memo and extracted them into this quick reference guide, including hotlinks to affected memoranda where possible.
Which Requirements have been Eliminated?
Acceleration of Payments to Small Businesses – Agencies are no longer required to provide quarterly progress reports to OMB on their acceleration of payments to small businesses and prime contracts awarded with small business subcontractors, as originally required by OMB M-12-16.
Conference Spending – Agencies no longer have to report this type of spending, as OMB appears willing to let the 2011 GSA conference scandal (which led to this requirement) be a thing of the past. Going forward, agencies are encouraged to conduct their own responsibility and diligence for conference spending in accordance with OMB Circular A-123.
Large Scale Construction Projects & Labor Agreements – Implementation guidance described in Executive Order (EO) 13502 is no more, relieving agencies of their requirement to report on a quarterly basis information related to “large-scale” construction projects and use of project labor agreements.
Contractor Performance and Integrity – The 100% target set in “Improving the Collection and Use of Information about Contractor Performance and Integrity” for reporting past performance on contracts over the simplified acquisition threshold is no more. However, OMB plans to work with agencies on efficient and effective management strategies addressing the use of past performance information, so acquisition professionals will want to look out for further guidance and direction here.
Which Requirements have been Modified?
Creating or Renewing Inter-agency and Agency Specific Contracts – The memo modifies how agencies must develop business cases when creating or renewing these types of instruments “to optimize the use of existing contracts and reduce duplication.” OMB will be piloting a new streamlined process consisting of Informed Analysis, Upfront Engagement, Facilitated Collaboration, & Optimization of Results. Below is a screen shot excerpt from the memorandum:
The pilot will begin on August 1, 2017 and run until March 1, 2019 at which point OMB will evaluate results with stakeholders and determine next steps.
Statistical & Narrative Reporting on Charge Cards – While agencies are still required to maintain this type of information for their own internal use, the impending modifications to the requirements described in Appendix B of OMB Circular A-123 will streamline and consolidate these requirements into a central location. Note that agencies are still required to report p-card violations as per M-13-21.
Which Requirements have been Paused?
Agency Acquisition Assessments – The requirement for agencies to conduct acquisition assessments under OMB Circular A-123 and integrate their assessment efforts into existing agency processes is paused through FY 2020. The intent is to enable agencies to focus on their reorganization planning and execution as per EO 13781.
Reporting on Non-Mission Travel – The requirement for agencies to report on semi-annual non-mission travel by senior officials and members of their family (to include any non-Federal travelers) is paused, although OMB intends to amend the enacting OMB Circular A-123 and eliminate the reporting requirement altogether.
Use of Value Engineering – The guidance at Section VIII of OMB Circular A-131 requiring an annual report on agency use of Value Engineering is paused. While the requirement will ultimately be eliminated, it will take some time for OMB to update the circular to eliminate the requiring language. However, OMB encourages agencies to continue overseeing its use of value engineering and sharing case studies on successful use cases in GSA’s Acquisition Gateway.
Read the full memorandum here and let us know if we missed anything in the comments section or in our discussion pages.
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