Acquisition Guidance in OMBs Revised Circular A-130

Toward the end of July and with little fanfare, the Office of Management and Budget (OMB) released an update to the federal government’s guidelines for the management of information resources. Called the Circular A-130, Managing Information as a Strategic Resource, the revised OMB guidance documents how federal agencies should incorporate management best practices into the acquisition, provisioning, maintenance, and, perhaps most importantly, modernization of their IT resources.

Concerning the acquisition of IT specifically, the A-130 outlines a vision for technology contracting that is intended to mesh seamlessly with other aspects of agency strategic planning; all with the goal of generating efficiency while reducing costs. One major directive in the A-130 concerns how agencies use their Information Resource Management (IRM) Strategic Plans. When these are kept up to date, IRMs can provide industry with an ongoing assessment of the progress agencies are making toward stated objectives. OMB now wants agencies to incorporate acquisition practices into their IRM plans, stipulating that agencies must a) confirm all awarded contracts align with goals outlined in the IRM plans and b) document how contract terms and conditions help meet stated IRM technology goals.

In other words, vendors who have a good grasp of the goals outlined in agency IRMs ought to be able to develop a clearer understanding of how past, current, and perhaps even future acquisitions fit into the larger strategic picture for agency IT environments.

Other guidance includes the following:

• Agencies are directed to incorporate agile development evaluations into normal acquisition processes. This could translate into more frequent rounds of market research, Q&A, and the release of draft documents for industry comment. Ideally, these practices will result in higher quality solicitations. In reality, they may also slow procurements as the number of iterative steps used by contracting offices grows.
• Agencies are required ensure that procurement workforces are properly trained and certified in IT acquisition. This measure is an effort to better educate contracting personnel about how acquisition practices should gel with IT project management. A major problem in the past with the use of lowest-price, technically acceptable (LPTA) based proposal evaluations has been that contracting personnel with little to no technical expertise have been determining contract awards. Better training can help solve this problem, but it could also make the use of LPTA evaluations more common.
• Lastly, agencies are to increase the use of modular contracting by breaking major IT investments into useful segments and awarding smaller contracts with limited durations. These awards are to be made within 180 days of solicitation release. Procurements that cannot be awarded within this timeframe are to be canceled. Modular contracting has become increasingly popular as agencies seek ways to reduce program risk and speed acquisition timeframes. The result for industry, however, is a greater number of solicitations to respond to and lower value awards. Proposal writing is already an arduous process. Greater use of modular contracting promises to make it even more so.