Post A-76 Actions
After the winner of the cost competition completes the transition period, the new
organization begins full performance duties. The Government then, regardless of
the outcome of the cost comparison, implements the Quality Assurance Surveillance
Plan (QASP). This plan should be reviewed periodically and updated as over the life
of the contract performance measures may no longer be accurate indicators of performance
and/or performance standards may no longer be valid.
If the Government MEO won the cost competition, the Government might be obligated
to conduct a Post-MEO Performance Review. A Post MEO Performance Review must be
conducted to ensure that the Government MEO has been implemented as proposed. The
Revised Supplemental Handbook mandates a Post-MEO Performance Review for 20% of
the in-house decisions. The Post MEO Performance Review ensures that the Government
MEO is meeting the same requirements that are expected of a contractor or ISSA provider
and any documentation to support a change in scope of effort.
Finally, the end of the A-76 process is to re-compete the function at the end of
the “contract” performance period. All award decisions can be re-competed at the
end of the “contract” regardless of MEO or contract performance; the same process
is followed in the re-competition as in the original cost comparison.
What is a Post- MEO Performance Review?
The Post-MEO Performance Review confirms that the MEO has been implemented in accordance
with the Transition Plan, establishes the MEO’s ability to perform the services
of the PWS and confirms that actual costs are within the estimates contained in
the in-house estimate. Adjustments may be made for formal mission or scope of work
changes. MEO performance may be measured in terms of workload, responsiveness, and
quality of work. Special inspections and a review of the activity’s implementation
of the Quality Assurance Surveillance Plan may be necessary. Cost conformance may
be determined by an analysis of actual labor and material costs against the Personnel,
Material, and Other Specifically Attributable costs on the final CCF. Care should
be taken to assure that adjustments are made for retained or saved pay and for fringe
benefit factors when using actual cost records. MEO implementation may also be measured
in terms of the FTE, grade structure, and the contract support included in the Transition
and Management Plan. Care must be taken to meet the same requirements that are expected
of a contractor. In practice, the MEO is treated the same as a contractor would
be treated, without the benefit of a contract awarded with guarantees for the length
of the performance periods listed in Schedule B of the RFP. Typically, this review
should be conducted following the end of the first full year of performance. A post
MEO review is mandated by the Supplemental Handbook. This process is currently undergoing
review and may be adjusted as necessary.
Why is it beneficial to maintain the PWS even after the competition is over?
Given the increased interest in post-MEO performance reviews, an MEO is under a
lot of pressure through the transition and first performance period. Maintaining
the PWS is the most effective way of documenting changes in workload and scope and
may be necessary to defend issues that arise during a post-MEO performance review.
For example, workload for a particular area may have doubled within the transition
period given an unforeseen event (base closure nearby or transfer of workload).
This increase in workload may be beyond what the MEO was able to account for in
its staffing and may be the reason why the MEO was not at the same number of FTE
as captured on the original CCF.
What is the difference between Quality Assurance (QA) and Quality Control (QC)?
QA and QC are frequently confused and mistakenly used interchangeably. They refer
to distinctly different actions performed by different organizations. QA involves
those actions taken by the government to inspect goods or services to determine
whether they meet the requirements of the PWS. QA is performed by the Government’s
QAEs. QC, on the other hand, refers to those actions taken by a contractor or the
MEO to control their production of goods or services so that they will meet the
requirements of the PWS. QC is performed by the contractor’s management team or
by the supervisors in the MEO. A simpler way to view it is the performing activity
(MEO or contract/ISSA) is responsible for QC (inspection at the time of performance.)
The receiving activity is responsible for QA (inspection of the delivered product
and/or service.) The Acceptance and Inspection clause in the award allows the Government
to implement quality assurance procedures.
Will there be a re-competition at some point in the future?
All award decisions will be subject to be re-competed at the end of the performance
period. The same process will be followed: data on workload, customer requirements,
internal requirements, etc. will be collected and analyzed and a new solicitation
will be issued. In the event of an MEO award during the first competition, a new
MEO will need to be developed and costed. Additionally, regardless of the first
competition outcome, the incumbent will receive the same benefits that accrued to
the government in the first competition. The process will remain virtually the same.
Only the participants will change. As the incumbent, the awardee of the first competition
will be required to provide all information necessary for inclusion on the CCF and
workload data to include in the solicitation. The assigned KO and designees will
be responsible for completing and issuing the new solicitation. Processes for capturing
data should have been included in all possible award decisions, i.e., the ISSA or
contractor will be required to provide detailed information on the work performed
in order to prove compliance with the standards in the PWS. The MEO should also
implement this same type of data collection tool in order to continually refine
the processes necessary to complete the requirements of the PWS. Maintaining the
PWS even after winning the first competition will greatly ease this part of the
process and provide the MEO with the best chance of most accurately responding to
the solicitation and minimizing appeals.
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