"Prior to public announcement (start date) of a Standard Competition, agencies shall:

(1) determine the activities and positions to be competed,

(2) conduct preliminary research to determine the appropriate grouping of activities as business units consistent with market and industry structures,

(3) assess the availability of workload data, work units, quantifiable outputs of activities or processes, agency or industry performance standards, and other similar data,

(4) establish data collection systems as necessary,

(5) determine roles and responsibilities of participants in the process and their availability for the duration of the process, and

(6) develop a preliminary completion schedule.

Prior to the latest Circular A-76 edition, the above steps were largely accomplished after the study announcement. The effort to determine the actual contract deliverables, to include the performance requirement, anticipated workload, agency task time standards, etc., plus establishing performance data systems and collecting the associated agency performance data consumed most of the time required to complete an A-76 study.  Especially for "white collar" type Government occupations, few agencies have the slightest idea, prior to developing an A-76 study, of what their specific products and services, vice processes, are, nor how performance of those products and services can be identified, measured, and quantified.

Frankly, the specifications for many of these studies merely re-stated existing instructions, regulations, manuals, and the like, with no specific performance oriented outcome and performance standard.  The new circular now requires agencies to conduct the majority of the  A-76 cost study preparations prior to the study announcement. The remaining effort to develop the contract specification and agency tender (the new name for the Management Plan, to include the most efficient organization (MEO)) is now limited to eight months, with the remaining four months for the solicitation and proposal review and acceptance periods.

If the preliminary planning effort has not been completed prior to announcement, there is no way the entire study can be done in eight months!!

Some agencies have undergone "business case analyses," developed "activity based costing," etc., that might lead them to conclude the preliminary planning steps have been taken and their functions are ready for announcement.  However, those programs do not get down to the required level of specific contract "deliverables" and their associated performance standards and projected annual workload.

Essentially, agencies should plan, now, which and when their eligible functions will be subjected to an A-76 study, and start the preliminary planning a minimum of one year prior to the anticipated study announcement dates.

2. The Source Selection Process and Performance Decision. Prior to the latest A-76 Circular, the source selection process only involved the commercial offerors, and only the selected "best value" offeror entered into competition with the A-76 studied function(s).  The Government was automatically considered in "the competitive range".  Since the Government's technical proposal plan was not reviewed concurrently with the commercial offerors, there was no "best value" consideration applied to that proposal.

Under the new A-76 Circular, all offers, to include the Government agency tender (the Government's technical and price proposal) will be reviewed concurrently.  If using source selection procedures that incorporate Cost/Technical Tradeoff (CTTO) features as described in FAR 15.101-1, the Government may award to other than the lowest priced offeror or other than the highest technically rated offeror, so long as the selected offer is within the agency's current budgetary limitations.

If the Source Selection Authority selects an offer based on other than low cost, the senior source selection official must certify this decision by providing: (1) a summary of the Source Selection Decision Document and (2) a narrative explanation of the tradeoffs and a quantifiable rationale for a selection decision based on other than lowest cost. The Government can choose a "best value" offeror if:

1. An offeror offers a feature that exceeds the Government's expectation(s).

2. An offeror has a better past performance record as compared to the other offerors.

3. Selecting the "Best Value" offeror poses a lower risk to the Government that the resulting contract will not be successful.

The Government's agency tender (the proposal) must respond to the same proposal submittal requirements as the commercial participants.  Since the Government now competes directly with the commercial participants, and is reviewed concurrently with the commercial proposals, it is very important the Government proposal emphasizes the MEO's past performance record, the quality of highly qualified employees that will be able to immediately provide the specified services at the required performance levels, how the continuity of service will not vary (vice a contract award decision), the MEO's superior knowledge of overall operations within and without the MEO, etc.