Independent Review
In this step, the Independent Review Officer (IRO) reviews all six of the major
deliverables of the cost comparison including: the Performance Work Statement (PWS),
the Quality Assurance Surveillance Plan (QASP), the Most Efficient Organization
(MEO), the In-House Cost Estimate (IHCE), the Technical Performance Plan (TPP),
and the Transition Plan (TP). This is done prior to submission of the Cost Comparison
Form (CCF) and supporting data to the Contracting Officer. The Government's cost
estimates must be certified in writing as in compliance with the procedures and
requirements described in the Revised Supplemental Handbook (RSH) to OMB Circular
A-76. The agency's A-76 Independent Review Officer (IRO), or designee, provides
this certification. The IRO should be a qualified person whose work and place in
the organization is independent of both the commercial activity being studied and
the cost comparison activity itself. When necessary, the IRO may need technical
assistance with the determination of the MEO's ability to perform the work in the
PWS at the cost proposed in the IHCE.
The purpose of this review is to certify that data contained in the Management Plan
reasonably establishes the government’s ability to perform the PWS within the resources
provided by the MEO and to ensure that all costs in the IHCE are fully justified.
This step concludes with the IRO returning the approved Management Plan documentation
to the CA team leader who seals the Management Plan and forwards it to the Contracting
Officer.
Who is the Independent Review Officer (IRO)?
The IRO is the agency official who certifies -- prior to bid opening -- that the
Government's performance and cost comparison estimates have been prepared in accordance
with OMB Circular A-76 and the Revised Supplemental Handbook.
Why is the cost comparison checked for accuracy?
The cost comparison process includes review by an independent authority to ensure
that the MEO developed can indeed perform the work as outlined in the Performance
Work Statement and that the Cost Comparison Form was prepared in accordance with
the Revised Supplemental Handbook and the DoD Costing Manual. The MEO team should
understand the need for an audit trail. All assumptions should be documented and
referenced ("Referenced" means that all assumptions should have an instruction,
regulation, or other official or non-official document that can be quoted.)
When is the Independent Review accomplished?
The"Independent Review" begins when the Government Management Plan is completed.
The Government Management Plan is completed when the certifying official signs the
cost comparison form. The certifying official should be an individual that has not
been a member of the MEO team and who can judge the cost effectiveness and efficiency
of the new organization. This individual signs the form and states that the in-house
organization reflected in the cost comparison is the most efficient and cost effective
organization that is fully capable of performing the scope of work and tasks required
by the Performance Work Statement. The individual also certifies that the proper
concurrence has been obtained and that the organizational structure can and will
be fully implemented.
Where can I learn about the independent review?
Refer to the Guide for Independent Review of Office of Management and Budget Circular
A-76 for information about independent reviews.
Can the Government Management Plan be changed after the independent review is
completed?
Changes to the Government Management Plan, including the In-House Cost Estimate
(IHCE), are permitted up to the bid due date for the receipt of initial Contract/ISSA
offers. (This"bid due date" is the closing date for proposals received in response
to a Request For Proposal or the bid opening date received in response to an Invitation
For Bid.) Allowable changes include any modifications to the Government's offer,
including revisions to the MEO, correction of calculation errors, and cost factor
changes directed by OMB including inflation factors, wage and salary tables, fringe
benefit factors and foreign exchange rates, if applicable. Any such changes require
recertification by the Independent Review Officer prior to the date for receipt
of the contract/ISSA offers.
Resources:
Policy
Guides and Recommended Readings