Department of Health and Human Services

[]{#__RefHeading___Toc168886892 .anchor}National Institutes of Health

[]{#__RefHeading___Toc168886893 .anchor}Competitive Sourcing Guidebook

Section G -- IHSP Implementation and Stand-Up

[National Institutes of Health i](#__RefHeading___Toc168886892)

[Competitive Sourcing Guidebook i](#__RefHeading___Toc168886893)

[Section G: Decision Implementation and Stand Up for an In-House Service
Provider
1](#decision-implementation-and-stand-up-for-an-in-house-service-provider)

[G.1. Policy 1](#policy)

[G.1.1 OMB Circular A-76 1](#omb-circular-a-76)

[G.1.2 NIH Policy 4](#nih-policy)

[G.2. Roles and Responsibilities 8](#roles-and-responsibilities)

[G.3. Procedures 17](#procedures)

[G.3.1 Overview 17](#overview)

[G.3.2 Implementation of the IHSP 19](#implementation-of-the-ihsp)

[G.3.3 Stand-Up the Organization 40](#stand-up-the-organization)

[G.4. Potential Pitfalls 41](#potential-pitfalls)

[G.5. Exhibits 41](#exhibits)

# Decision Implementation and Stand Up for an In-House Service Provider

  -------------- ----------------------------------------------------------------
  **Objectives   
  for this       
  Section**      

  ****          Implementation Policy

  ****          Roles and Responsibilities

  ****          Procedures

  ****          Potential Pitfalls
  -------------- ----------------------------------------------------------------

This Guidebook section discusses the implementation of an in-house
decision, including the implementation of the Most Efficient
Organization (MEO) and post-competition monitoring associated with
performance under a Letter of Obligation (LOO). The Implementation Team
includes personnel from the organization implementing the MEO, the
Contracting Officer (CO), the Human Resources Advisor (HRA), and a
representative from the Commercial Activities Review Team (CART). The
primary goals for the Implementation Phase are:

-   Establish the Letter of Obligation

-   Implement staffing changes proposed by the MEO

-   Implement any process changes, training, equipment changes, or other
    MEO proposals

-   Complete any transition or phase-in period reports required in the
    Performance Work Statement (PWS) or Requirements Document (RD)

-   Prepare to implement post-competition monitoring of the MEO,
    including cost monitoring, quality assurance, and workload tracking

-   Train MEO and other personnel regarding their new duties

The end result of the implementation phase is the "stand-up" of the MEO,
which becomes known as the In-House Service Provider (IHSP).

## Policy

### OMB Circular A-76

The following are specific sections of OMB Circular A-76 revised May,
2003 (the Circular) associated with the implementation phase. ***If you
are unfamiliar with the terms used in this Section, please refer to
Section A, Competitive Sourcing Overview, and to the rest of this
chapter, which covers the requirements in more detail.*** These sections
are mandatory and must be followed in all Implementation and
Post-Competition work.

> ATTACHMENT B, SECTION A.8.d (1) Employee and Labor-Relations
> Requirements. The Human Resources Advisor shall, at a minimum, perform
> the following (a) interface with directly affected employees (and
> their representatives) from the date of public announcement until full
> implementation of the performance decision; (b) identify adversely
> affected employees; (c) accomplish employee placement entitlements in
> accordance with 5 C.F.R. Part 351 (reduction-in-force procedures); (d)
> provide post-employment restrictions to employees; (e) determine
> agency priority considerations for vacant positions and establish a
> reemployment priority list(s) in accordance with 5 C.F.R. Part 330;
> and (f) provide the Contracting Officer with a list of the agency's
> adversely affected employees, as required by this attachment and FAR
> 7.305(c) regarding the right of first refusal for a private sector
> performance decision.
>
> ATTACHMENT B, SECTION A.8.d (2) MEO Team Requirements. The Human
> Resources Advisor shall assist the ATO \[Agency Tender Official\] and
> MEO \[Most Efficient Organization\] team in developing the agency
> tender. During development of the agency tender, the Human Resources
> Advisor shall be responsible for ... (d) performing labor market
> analysis to determine the availability of sufficient labor to staff
> the MEO and implement the phase-in plan; ... (f) assisting in the
> development of the timing for the phase-in plan based on MEO
> requirements; and (g) developing an employee transition plan for the
> incumbent agency organization early in the standard competition
> process.
>
> ATTACHMENT B, SECTION D. 3.a. (13) Phase-in Plan. The Contracting
> Officer \[Contracting Officer\] shall include in the solicitation a
> separate CLIN \[Contract Line Item Number\] for a phase-in plan.
> Private sector, public reimbursable and agency sources shall propose a
> phase-in plan to replace the incumbent service provider. The
> Contracting Officer shall designate the phase-in period as the first
> performance period (see Attachment C). The CLIN is limited to the
> phase-in costs associated with phase-in actions as documented in the
> phase-in plan. Phase-in plans shall include details to minimize
> disruption and start-up requirements. The phase-in plan shall consider
> recruiting, hiring, training, security limitations, and any other
> special considerations of the prospective providers to reflect a
> phase-in period of realistic length and requirements. (Applies to
> Standard Competitions.)
>
> ATTACHMENT B, SECTION D. 4.a. (1) (d) Phase-in Plan. The ATO shall
> include a phase-in plan in the agency tender, as required by the
> solicitation, to replace the incumbent service provider with the MEO,
> even if the agency is the incumbent service provider. The ATO shall
> include phase-in costs for the agency tender on SCF \[Standard
> Competition Form\] Lines 1-6.
>
> ATTACHMENT B, SECTION E. POST COMPETITION ACCOUNTABILITY FOR
> STREAMLINED AND STANDARD COMPETITIONS.
>
> 1\. Best Practices and Lessons Learned. Agencies shall post best
> practices and lessons learned resulting from a streamlined or standard
> competition process on SHARE A-76! at
> http://emissary.acq.osd.mil/inst/share.nsf/. An agency shall maintain
> the accuracy and currency of their agency's information, including
> links, on SHARE A-76!
>
> 2\. Execution Tracking of Streamlined and Standard Competitions.
> Agencies shall maintain a database to track the execution of agency
> streamlined and standard competitions. Agencies shall maintain a
> database that (1) assigns a unique tracking number to each streamlined
> and standard competition, (2) includes data fields as defined on the
> OMB web site at www.omb.gov, (3) tracks each streamlined and standard
> competition as events occur (real-time) from the date of public
> announcement through either completion of the last performance period
> or cancellation of the competition, and (4) retains historical records
> of streamlined and standard competitions after the last performance
> period has been completed.
>
> 3\. Competitive Sourcing Quarterly Report. An agency shall submit a
> Competitive Sourcing Quarterly Report to OMB, by the end of each
> fiscal quarter (December, March, June, September), that includes the
> following (1) in-progress streamlined and standard competitions (i.e.,
> competitions with start dates and pending performance decisions); and
> (2) completed streamlined and standard competitions (i.e.,
> competitions with performance decisions). The required format for
> these reports can be found on the OMB web site at www.omb.gov.
>
> 4\. Monitoring Performance. Regardless of the selected service
> provider, after implementing a performance decision, an agency shall
> (1) monitor performance for all performance periods stated in the
> solicitation; (2) implement the quality assurance surveillance plan;
> (3) retain the solicitation and any other documentation from the
> streamlined or standard competition as part of the competition file;
> (4) maintain the currency of the contract file, consistent with FAR
> Subpart 4.8, for contracts, MEO letters of obligation, and
> fee-for-service agreements; (5) record the actual cost of performance
> by performance period; and (6) monitor, collect, and report
> performance information, consistent with FAR Subpart 42.15, for
> purposes of past performance evaluation in a follow-on streamlined or
> standard competition. To record the actual cost of performance for a
> specific performance period, the agency shall adjust actual costs for
> scope, inflation, and wage rate adjustments made during a specific
> performance period. The agency shall compare the actual costs to the
> costs recorded on SCF Lines 6 and 7 when the performance decision was
> made.
>
> 5\. Option Years of Performance and Follow-on Competition.
>
> a\. Option Years of Performance. The Contracting Officer shall make
> option year exercise determinations for agency, public reimbursable,
> and private sector performance decisions in accordance with FAR
> 17.207. Consistent with the FAR, the Contracting Officer shall not
> approve performance periods that exceed the total number of years
> specified in the solicitation used in the standard competition.
>
> b\. Follow-on Competition. For agency or public reimbursable
> performance decisions, an agency shall complete another streamlined or
> standard competition of the activity by the end of the last
> performance period on the SCF or SLCF unless a specific exemption is
> granted by the CSO (without delegation) before the end of the last
> performance period. The CSO may extend the performance period for a
> high performing organization if the CSO (a) determines that continued
> cost savings justifies the extension; (b) documents these cost savings
> through the use of a COMPARE generated SCF or SLCF; (c) limits the
> extension to no more than 3 years after the last performance period;
> and (d) makes a formal announcement of the extension via
> FedBizOpps.gov. For private sector performance decisions, the
> Contracting Officer shall comply with the FAR for follow-on
> competition.
>
> 6\. Terminations.
>
> a\. Terminations Based on Failure to Perform.
>
> \(1\) Notification. Consistent with FAR Part 49, the Contracting
> Officer shall notify a service provider (i.e., private sector
> contractor, public reimbursable provider, or MEO) of poor performance
> through cure notices and show cause notices. The Contracting Officer
> shall inform the head of the requiring activity of such notices.
>
> \(2\) Termination. If the Contracting Officer determines that a
> service provider (i.e., private sector contractor, public reimbursable
> provider, or MEO) has failed to perform to the extent that a
> termination for default is justified, the Contracting Officer shall
> issue a notice of termination, consistent with FAR Part 49. Upon
> terminating an MEO letter of obligation, an agency shall change the
> inventory coding to reflect that the activity is no longer performed
> by an MEO and shall perform either a streamlined or standard
> competition.
>
> \(3\) Temporary Remedies. If the Contracting Officer terminates a
> contract, fee-for-service agreement, or MEO letter of obligation for
> the service provider's failure to perform, an agency may use interim
> contracts, public reimbursable sources, or government personnel on an
> emergency basis. An agency shall not allow these temporary remedies to
> be used for longer than one year from the date of termination.
>
> b\. Terminations Based on Reasons Other than Failure to Perform. If an
> agency determines that performance by a service provider (i.e.,
> private sector contractor, public reimbursable, or MEO) is to be
> terminated for reasons other than failure to perform, the CSO (without
> delegation) shall approve such terminations, in writing, and provide a
> copy to OMB before the termination. Examples of these terminations
> include, but are not limited to, elimination of an agency requirement
> through divestiture, privatization, reorganization, restructuring,
> national defense, or homeland security.
>
> ATTACHMENT D, SECTION B. Employee Transition Plan. A written plan
> developed by the Human Resources Advisor for the potential transition
> of the agency's civilian employees to an MEO, or to private sector or
> public reimbursable performance. This plan is developed early in the
> streamlined or standard competition process, based on the incumbent
> government organization, to identify projected employee impacts and
> the time needed to accommodate such impacts, depending on the
> potential outcomes of the competition. The employee transition plan
> differs from a phase-in plan, which is developed by prospective
> providers responding to a solicitation.
>
> ATTACHMENT D, SECTION B. Phase-in Plan. A prospective provider's plan
> to replace the incumbent provider(s) that is submitted in response to
> the solicitation. The phase-in plan is implemented in the first
> performance period and includes details on minimizing disruption,
> adverse personnel impacts, and start-up requirements. The phase-in
> plan is different from the employee transition plan developed by the
> Human Resources Advisor.

### NIH Policy

The following are additional post-competition policies set by NIH in
order to implement the Circular in the NIH environment.

#### In-House Service Provider (IHSP) Administration Structure

For all in-house decisions, a Letter of Obligation shall be issued by
the Contracting Officer to a Responsible Official designated by the
Deputy Director for Management (DDM). The Responsible Official acts in a
similar capacity to a corporate officer or partner in a private firm. He
or she is responsible for performance and has the authority to negotiate
on behalf of the IHSP. The Letter of Obligation shall obligate the IHSP
to perform the work in the Performance Work Statement or Requirements
Document (PWS/RD). It is to be signed by the Responsible Official and
Contracting Officer (CO).

IHSPs shall be monitored during the performance periods specified in a
Letter of Obligation using methods similar to those used to monitor a
commercial contractor. NIH will, therefore, maintain a separation
between IHSP administration and IHSP performance of work. This
separation is designed to ensure that no conflict of interest, nor
appearance of conflict of interest, occurs during the performance of
work by an IHSP.

Specifically, the Responsible Official, Contracting Officer, and Project
Officer must be separate individuals, and the Project Officer and
Contracting Officer must not report to the Responsible Official.
Officials who perform IHSP administration on an IHSP may not serve in
the IHSP, and vice versa. Roles cannot be combined across the IHSP/ IHSP
"Contract" Administration line.

Roles may be combined on each side of the line. For example, the
Responsible Official may be the MEO Manager, and the Project Officer may
perform the duties of a Quality Assurance Evaluator. The delineation of
the IHSP administration/IHSP relationships is shown below. These are not
necessarily supervisory relationships; they reflect contracting
responsibilities.

Figure G-1: Post-Implementation "Contractual" Relationships

The IHSP has two distinct components that are parallel to the components
of a private sector firm. There is the work that is done under the
Letter of Obligation -- work that is directed by the PWS/RD -- and there
is a "corporate" structure that surrounds the work. In the above chart,
work associated with the PWS/RD is within the shaded area labeled "In
Scope." Costs associated with personnel who are included in that portion
of the IHSP were included as direct personnel in the Agency Cost
Estimate.

The Responsible Official represents the larger "corporate" framework of
the IHSP. He or she is does not necessarily perform any work that is
within the scope of the PWS/RD, but instead provides the corporate
oversight necessary to ensure that the work is completed satisfactorily.

The dotted line relationship between the Project Officer and the MEO
Manager indicates the day-to-day working relationship that exists in a
good contract relationship. Under most circumstances, the Responsible
Official and the Contracting Officer will become involved only when
formal contract action is necessary to resolve a situation. The rest of
the time, the Project Officer and MEO Manager, working within the scope
of the PWS or RD, will handle and resolve day-to-day matters without
recourse to higher-level officials or formal contract-related actions.

#### Implementation Activities

During Implementation, the Implementation Team, with the support of the
Human Resources Advisor, Project Officer, Contracting Officer,
Commercial Activities Review Team (CART), Commercial Activities Steering
Committee (CASC), Transition Center, IC participants, and affected
organizations and employees, shall complete all activities required to
begin operations under the requirements of the PWS/RD with the
structures proposed in the Agency Tender and Agency Cost Estimate. These
activities include, but are not limited to, Letter of Obligation
signature, staffing the IHSP and IHSP "Contract" Administration
structures, reviewing and implementing changes required by the PWS/RD
and Agency Tender/Agency Cost Estimate, communicating with affected
individuals and groups, determining training requirements, coordinating
logistical changes, developing plans required by the PWS/RD or
solicitation, and ensuring that all government property changes are made
as required by the PWS/RD and Agency Tender/Agency Cost Estimate.

#### Implementation Team Personnel

The Implementation Team Members, MEO personnel, and others who play a
role in implementation are appointed as shown in the following charts.

Other roles, and the parties responsible for approval of personnel
assigned to the roles, are shown in the charts below.

+----------------------+-------------------------+--------------------+
| **Role**             | **Process**             | **Timeline**       |
+----------------------+-------------------------+--------------------+
| Project Officer      | Identified by           | Preliminary        |
|                      | Preliminary Planning    | Planning           |
|                      | Team                    |                    |
|                      |                         |                    |
|                      | Approved by the DDM     |                    |
+----------------------+-------------------------+--------------------+
| Responsible Official | Identified by           | Preliminary        |
|                      | Preliminary Planning    | Planning           |
|                      |                         |                    |
|                      | Team                    |                    |
|                      |                         |                    |
|                      | Approved by the DDM     |                    |
+----------------------+-------------------------+--------------------+
| Implementation Team  | Responsible Official    | After competition  |
| Lead                 | serves as               | decision(1)        |
|                      | Implementation Team     |                    |
|                      | Lead, or delegation     |                    |
|                      | with approval by DDM    |                    |
|                      | with notification to    |                    |
|                      | the NIH Director        |                    |
+----------------------+-------------------------+--------------------+
| Implementation Team  | Responsible Official    | After competition  |
|                      |                         | decision(1)        |
+----------------------+-------------------------+--------------------+
| MEO                  | Standard hiring         | After competition  |
| Manager/Supervisors  | practices               | decision(1)        |
+----------------------+-------------------------+--------------------+
| Human Resources      | Standard OSMP practices | Preliminary        |
| Advisor              |                         | Planning(1)        |
+----------------------+-------------------------+--------------------+
| Contracting Officer  | Standard contracting    | Preliminary        |
|                      | practices               | Planning(1)        |
+----------------------+-------------------------+--------------------+
| Quality Assurance    | Standard contracting    | After competition  |
| Evaluators           | practices               | decision(1)        |
+----------------------+-------------------------+--------------------+
| Project Officer\'s   | Standard contracting    | After competition  |
| Advisory Group       | practices               | decision(1)        |
+----------------------+-------------------------+--------------------+

#### Implementation Timeframes

The Implementation Timeframe is determined by the type of competition
conducted. The following table shows the maximum duration of an
implementation by the type of competition:

  ------------------ ---------------- ----------------- ------------------
  **Competition      **\# of FTE**    **FTE Change**    **Maximum Length
  Type**                                                of
                                                        Implementation**

  As-Is Organization Any              Any               2 months

  Streamlined with   Any              Any               6 months
  MEO                                                   

  Standard           Any              Any               6 to 12 months
  ------------------ ---------------- ----------------- ------------------

Implementation efforts should be implemented more quickly, when
possible. Deviations from this policy must be presented to the CASC for
recommendation for approval by the DDM. Letter of Obligation Kickoff
meetings shall occur 14 days (10 business days) after a performance
decision.

#### Affected Personnel

It is HHS policy that all affected personnel will be offered employment
within HHS. It is NIH policy to find employment for affected personnel
within NIH whenever possible.

##### Immediate Reassignment of Affected Personnel

Unless circumstances dictate otherwise, affected employees that require
placement outside of the MEO will be reassigned to new permanent
positions throughout the NIH as of the implementation date of the MEO.
Under this approach:

-   Employees will be immediately reassigned to ICs/OD where they will
    be employed and housed.

-   The ICs/OD will be responsible for developing a permanent position
    for employees assigned to them.

-   Training to develop skills necessary for the target position and
    other employee services will be available to employees through the
    NIH Transition Center

-   The OD, in addition to managing the NIH Transition Center, will
    provide guidance and assistance such as the development of generic
    job descriptions, minimum training requirements, etc. to assure a
    corporate-wide approach to managing the transition.

##### Allocation of Placements

The assignment of employees will be proportional across the ICs/OD to
the degree possible. If the assignment of employees is less than
proportional, a reallocation of FTEs from all ICs to the receiving ICs
may be necessary to avoid inequities.

##### Costs

Training costs for needs assessment, career counseling, re-training, and
outplacement support for transition employees will be covered through
central services funds.

#### Lessons Learned

Posting of Lessons Learned at the Share A-76! Website is to be completed
by the CART. Others wishing to post lessons learned shall submit their
materials to the CART for review and approval.

## Roles and Responsibilities

The following individuals and groups will serve as guides, resources,
and key players during the Implementation Process. Some of these
individuals or groups have been involved throughout the competition
process and may be able to provide background information on decisions
made, an understanding of the overall A-76 process, or other helpful
information. The Implementation and Post Competition phases are
dependent on these groups and individuals working together and
coordinating their efforts.

Additional details on the individual and group responsibilities are
included throughout this section and in Exhibit G-7, which includes one
page descriptions of responsibility for the key players. This list will
provide a brief overview and serve as a quick reference for the reader.

-   *Deputy Director for Management (DDM)*: The DDM has the ultimate
    responsibility for the A-76 program at the NIH, as delegated by the
    NIH Director, who serves as the NIH Competitive Sourcing Official
    (CSO). The DDM may bring issues that require higher-level review to
    the NIH Steering Committee, Management and Budget Working Group, the
    NIH Deputy Director, or the NIH Director, as appropriate. The DDM
    appoints the Responsible Official and Project Officer for all
    in-house decisions.

-   *Executive Officers (EO):* The EO is normally the highest-level IC
    point of contact for an IHSP; however, the EO may or may not be in
    the Supervisory chain of IHSP personnel and operations, depending on
    the specific structure of the IHSP. The EO receives and certifies
    the list of all affected employees within the IC and nominates IC
    representatives for formal A-76 related roles. The EOs coordinate
    the receipt of displaced employees, transition from the Transition
    Center, and ensure that displaced personnel are appropriately
    appointed into a position within the IC. The EOs provides feedback
    to the Project Officer regarding requests for PWS/RD modifications
    and MEO deviations. The EO may provide supporting documentation or
    initiate tracking of new work to justify a modification. The EO
    coordinates with the IHSP Manager, Supervisor, Project Officer, or
    Contracting Officer as necessary regarding potential modifications
    and deviations, or services to their IC. If the EO is within the
    supervisory chain of the MEO, the EO may have additional oversight
    responsibilities.

-   *Commercial Activities Steering Committee (CASC):* The CASC's
    responsibility, by charter, is to recommend policy to the DDM and
    make operational decisions to ensure that NIH successfully meets its
    responsibilities under the FAIR Act and under the Competitive
    Sourcing component of the President's Management Agenda, as outlined
    in OMB Circular A-76. The CASC will recommend resolution of disputes
    that cannot be settled by the Project Officer, with the input of the
    Management Advisory Board. The Project Officer or a majority of the
    Management Advisory Board have the authority to bring matters to the
    CASC for resolution.

-   *Office of Management Assessment (OMA)/Commercial Activities Review
    Team (CART):* CART Representatives are the NIH overall project
    leaders of the A-76 process. The CART provides assistance to the
    Implementation Team throughout the process, develops implementation
    policy, gathers and analyzes the data necessary for NIH-wide A-76
    program reporting, and provides technical guidance to the Project
    Officer for developing tracking systems. On an exception basis, the
    CART provides staff support to the Project Officer for performance
    of quality assurance, performance tracking, and cost monitoring.
    This includes clarification of reporting and processes, guidance,
    and direction on timelines and schedules

-   *Transition Center:* The Transition Center provides services,
    resources, and tools to assist NIH employees who are affected by
    Competitive Sourcing decisions. The Services are specifically
    designed to support and facilitate the placement and, when needed,
    retraining of employees. Services include training on developing and
    loading resumes, responding to KSAs, and retirement workshops. For
    placements outside of the restructured organization, services
    include comprehensive career transition workshops, educational or
    career counseling and coaching, skills, aptitudes, and interests
    assessments, and tailored skill and job development.

-   *Office of Strategic Management Planning (OSMP) / Human Resources
    Advisor (HRA):* The Human Resources Advisor is an OSMP employee
    designated to coordinate the staffing of the IHSP through
    development of the Employee Transition Plan, and ensures that all
    personnel actions are handled appropriately and on time. The Human
    Resources Advisor provides guidance and procedures for handling
    personnel actions in the course of implementation. This includes the
    determination and application for Voluntary Early Retirement
    Authority (VERA)/Voluntary Separation Incentive Pay (VSIP), freeze
    exceptions, vacancy announcements, and certifications. The Human
    Resources Advisor consults and coordinates with OHR to validate
    Employee Transition Plans and qualifications, provide assistance and
    training on voluntary changes to lower grade and retirement,
    announce vacancies, develop certificates, and effect selections,
    placements, and other personnel actions. The Human Resources Advisor
    coordinates activities with the Transition Center Director or
    representative to identify, notify, and place transition status
    staff. The Human Resources Advisor coordinates the placement of
    displaced employees.

-   *Labor Relations/Union*: An important player in the implementation
    process if there are Union employees in the affected population.
    There may be multiple individuals associated with the Labor
    Relations Office that are involved.

-   *Office of Logistics and Acquisition Operations (OLAO) / Contracting
    Officer (CO):* The Contracting Officer is an OLAO employee who is
    designated to oversee the acquisition process. After the performance
    decision, the Contracting Officer awards the contract or establishes
    the Letter of Obligation with the IHSP. The Contracting Officer, as
    the overall authority over the contract or Letter of Obligation,
    monitors the Implementation and performance of the Service Provider,
    approves all modifications and deviations, verifies that the work
    performed meets the standards in the PWS or RD, monitors costs,
    makes option year determinations, issues notices of termination, and
    maintains the contract and competition files.

-   *Project Officer (PO):* The Project Officer assists the Contracting
    Officer in overseeing the Implementation and Stand Up process. The
    Project Officer serves as the primary technical representative
    assigned to monitor the overall performance of the MEO and is the
    main point of contact between the Contracting Officer and the MEO
    Manager. The Project Officer has delegated contract-related
    authority and responsibility for ongoing performance monitoring,
    cost tracking, and other contract-type oversight. The Project
    Officer coordinates with the MEO Manager on a day-to-day basis to
    ensure that work required by the PWS/RD is completed satisfactorily.
    The Project Officer serves as the chair of the Advisory Group, when
    needed. The Project Officer oversees development and recommends
    approval of all modifications to the PWS/RD and resources required
    to complete work. The Project Officer reviews new and changed
    requirements to determine potential changes to the scope of the PWS
    or RD.

-   *IHSP Advisory Group:* The IHSP Advisory Group advises the Project
    Officer on management issues associated with performance, staffing,
    and services provided by the implemented organization. The Project
    Officer is the chair of the Advisory Group. The IHSP Advisory Group
    is different than the Decision Implementation Team and provides an
    additional resource to the Project Officer when making decisions,
    particularly when such issues affect multiple ICs. An Advisory Group
    will not normally be set up for an MEO that is whole or mostly
    contained within a single IC.

-   *In-House Service Provider (IHSP):* The term used to describe the
    MEO or "as-is" organization (an "as-is" organization is one that
    made no changes during the competition) that competed and won an
    A-76 competition. The IHSP includes both "in-scope" (i.e., work that
    is required in the PWS/RD) and the "corporate" structure associated
    with the Responsible Official's duties.

-   *Responsible Official*: The official responsible for signing the
    Letter of Obligation and leading the implementation effort; the
    individual ultimately responsible for the MEO. The Responsible
    Official provides information to the community regarding IHSP
    services and lines of work. The Responsible Official represents the
    larger "corporate" framework of the IHSP. He or she is does not
    necessarily perform any work that is within the scope of the PWS/RD,
    but instead provides the corporate oversight necessary to ensure
    that the work is completed satisfactorily. In many cases, the Agency
    Tender Official (ATO) becomes the Responsible Official, or could be
    the MEO Manager or Project Officer. The term "ATO" is typically not
    used after the award decision or after an MEO Manager or Project
    Officer is named.

-   *MEO Manager/Supervisors:* The MEO Manager is the highest position
    or supervisor in the MEO. The MEO Manager may be the original signer
    of the Letter of Obligation or may have this responsibility
    delegated to him or her. The MEO Manager usually serves as the chair
    of the Implementation Team and oversees day-to-day efforts to ensure
    that the MEO performs within the limits proposed by the Agency
    Tender to accomplish the work in the PWS/RD. The MEO Manager
    coordinates with the Project Officer on a day-to-day basis to ensure
    that work required by the PWS/RD is completed satisfactorily. The
    MEO Manager provides reports to the Project Officer regarding IHSP
    work counts and overall work being provided. The MEO Manager gathers
    cost data and provides quarterly cost monitoring reports to the
    Project Officer. The MEO Manager documents deviations from the
    PWS/RD, MEO, and Technical Proposal, monitors staffing and resource
    requirements, and reports deviations to the Project Officer. The MEO
    Manager responds to comments, complaints, requests for modification,
    and other customer input.

-   *Implementation Team:* The Implementation Team is the group of
    individuals assembled to assist in the transition from the current
    organization to the IHSP and "stand-up" the organization. The
    Implementation Team Leader heads the implementation effort and
    ultimately selects the Team.

The relationships between major post-competition roles are particularly
important; these personnel play an ongoing role in the In-House Service
Provider's performance. Post-competition roles are modeled after a
standard contract relationship, since the Circular defines an
essentially contractual relationship for performance of work after A-76
cost comparison. This involves an administration effort (known as the
IHSP Administration) that will be comprised of the Contracting Officer,
the Project Officer, and Quality Assurance Evaluator(s) and an IHSP
effort that involves the Responsible Official, IHSP Managers and
Supervisors, and the IHSP staff.

A formalized relationship between these two groups is created when the
Letter of Obligation is issued by the Contracting Officer and signed by
the Responsible Official. The rest of the interactions between the
groups derive from the Letter of Obligation, from the delegation of IHSP
administration authority from the Contracting Officer to the Project
Officer and Quality Assurance Evaluators, and in the supervisory
relationships within the IHSP. Figure G-1 shows the relationships
between these parties. The DDM, through OMA and its CART, and with the
advice of the CASC as necessary, coordinates and oversees resolution of
issues that arise between the IHSP administration and IHSP elements of
post-competition performance, with the DDM serving as the final arbiter
of disputes.

Figure G-1: Post-Implementation "Contractual" Relationships

The IHSP has two distinct components that are parallel to the components
of a private sector firm. There is the work that is done under the
Letter of Obligation -- work that is directed by the PWS/RD -- and there
is a "corporate" structure that surrounds the work. In the above chart,
work associated with the PWS/RD is within the shaded area labeled "In
Scope." Costs associated with personnel who are included in that portion
of the IHSP were included as direct personnel in the Agency Cost
Estimate.

The Responsible Official represents the larger "corporate" framework of
the IHSP. He or she does not necessarily perform any work that is within
the scope of the PWS/RD, but instead provides the corporate oversight
necessary to ensure that the work is completed satisfactorily.

The dotted line relationship between the Project Officer and the MEO
Manager indicates the day-to-day working relationship that exists in a
good contract relationship. Under most circumstances, the Responsible
Official and the Contracting Officer will become involved only when
formal contract action is necessary to resolve a situation. The rest of
the time, the Project Officer and MEO Manager, working within the scope
of the PWS or RD, will handle and resolve day-to-day matters without
recourse to higher-level officials or formal contract-related actions.

Supervisory relationships are not shown in Figure G-1; there are
multiple possible supervisory relationships that may arise depending on
the specific structure of the IHSP and the organizations it supports.
For example, two likely scenarios arise for a centralized IHSP. In the
first instance, shown in Figure G-2, the Project Officer and Responsible
Official both report to a higher-level Management Official within an IC.
The Responsible Official ensures that the IHSP performs its work
satisfactorily, while the Project Officer ensures that NIH is receiving
the work required in the PWS/RD, and ensures that customers are
receiving the services that they need.

The Contracting Officer, DDM, CART, and CASC are all outside of this
formal supervisory chain, but maintain their working relationships for
the purposes of completing post-competition tasks.

In each case, there are certain separations that should be maintained.
Although there are no formal requirements to maintain a firewall or
separation in the Circular or the Federal Acquisition Regulation, there
is still a need to ensure that there is no real or apparent conflict of
interest between the IHSP and the IHSP "Contract" Administration.
Because of this, it is NIH policy that the Project Officer must not
report to the Responsible Official. In addition, officials on the
administration side of an IHSP may not serve on the performance side of
an IHSP, and vice versa. The Responsible Official and Project Officer
must be separate. Roles cannot be combined across the IHSP/LOO
Administration line. On each side of the line, roles may be combined.
For example, the Responsible Official may be the MEO Manager, and the
Project Officer may perform the duties of a Quality Assurance Evaluator.

Figure G-2: Post-Implementation Supervisory Relationships in a
Centralized IHSP (Example 1)

In the second example, shown in Figure G-3, the Project Officer
supervises the Responsible Official, and the rest of the relationships
remain the same.

Figure G-3: Post-Implementation Supervisory Relationships in a
Centralized IHSP (Example 2)

The structure of a decentralized IHSP (shown in Figure G-4) leads to a
more complex management structure and set of relationships. The
structure in Figure G-4 illustrates reporting and coordination
requirements required when a function continues to be performed in
multiple ICs without consolidation or restructuring. The Points of
Contact listed in the IHSP are supervisors or managers who are over the
IHSP. In the example shown, the POCs are not a direct part of the IHSP.
This will allow the EO or management official to designate one person as
the POC for multiple studies, if he or she chooses to do so. IC POCs may
also be in-scope managers and supervisors for an IHSP. Under most
circumstances, the Project Officer and Quality Assurance functions
should be located in the IC with the preponderance of the IHSP effort.

Figure G-4a: Post-Implementation Supervisory Relationships in a
Decentralized IHSP (Alternative 1: Project Officer and QA under each EO)

Figure G-4b: Post-Implementation Supervisory Relationships in a
Decentralized IHSP (Alternative 2: Project Officer and QA centralized
under the CART)

## Procedures

### Overview

At this point in the competition process, the performance decision has
been made and the competition has officially entered the *Post
Competition* phase. This Chapter discusses the Implementation activities
that occur when there is an Agency decision. In-House Service Provider
(IHSP) is the term used to identify the Agency's Most/More Efficient
Organization (MEO) or as-is organization that has been selected as the
winner of the competition. The beginning of the Post-Competition period
is referred to as *Phase-In*, *Transition,* or *Implementation,*
depending on Agency practice. NIH refers to the period between Award and
the Start Date as [Implementation]{.underline}.

***Relevant Terms and Documents***

Prior to getting started on the tasks listed in this section, it may be
helpful to review some of the terms and related documents discussed in
this section.

-   *Post Competition.* The period of time following the performance
    decision or Award, which continues for the duration of the contract
    or Letter of Obligation.

-   *Decision Implementation or Phase-In Period.* The time between Award
    and the Service Provider's start date, where the functional
    operations are prepared to transfer to the Service Provider's
    organization and operation. The duration of this period is typically
    dependent on the type and size of a study and is usually specified
    in the solicitation. The Phase-In Plan is typically executed after
    Award.

-   *Letter of Obligation.* A Letter of Obligation is the formal
    agreement between the in-house Government Service Provider
    (incumbent organization or MEO) and the contracting office regarding
    the work requirements that were the basis for the competition. It
    is, in effect, the Government's "contract" with the "winning"
    Government Service Provider. It holds the IHSP accountable for the
    work defined in the PWS or RD and the costs "offered" to perform
    that work.

-   *Phase-In Plan*. The Phase-In Plan is the Service Provider's plan to
    replace the incumbent provider, which is typically submitted in
    response to the solicitation. The Phase-In Plan is implemented
    during the first performance period and includes details on
    minimizing disruption, adverse personnel impacts, and start-up
    requirements.

-   *Employee Transition Plan (Staffing Plan)*. A written plan developed
    by the Human Resources Advisor for the potential transition of the
    agency's civilian employees into the MEO, or into a private sector
    or public reimbursable organization. The plan is developed early in
    the competition process. The Employee Transition Plan is revised and
    refined during the implementation period with the input of the
    Implementation Team. This Plan is prepared by the Human Resources
    Advisor in coordination with the Transition Center. It outlines the
    options and plans for placing employees, from direct reassignment to
    advertising for positions. The DDM has the final approval authority
    for all Employee Transition Plans.

-   *Start Date:* Sometimes referred to as the "stand-up date," "full
    performance date," or the beginning of the "first period of full
    performance;" the date upon which the new Service Provider assumes
    full responsibility for the performance of work described in the
    Performance Work Statement (PWS)/Requirements Document (RD).

The complexity of the work to be done (and therefore the amount of work
required) during Implementation will depend on the type and size of the
competition. For example, a Streamlined Competition with ten employees
will likely be much easier to implement than a Standard Competition with
100 employees. Furthermore, each Implementation will have its own unique
activities and requirements based on the organization being implemented.

***Implementation Process***

As mentioned previously, the Implementation period is the time for the
IHSP to transition from the current organization at time of Award to the
proposed organization by Stand-Up. There are many activities and tasks
to be completed during this period of time, which will be discussed
throughout this Section. The following flow-chart provides an overview
of the activities and milestones one should expect during
Implementation. Throughout this Section, flow charts will be included to
highlight the steps and milestones within a certain area of
responsibility.

Figure G-5 Implementation Process

![](media/image1.wmf)

***Implementation Timeframe***

The duration of the Implementation Period is determined by the type of
competition conducted. The following table shows the maximum duration of
an implementation by the type of competition:

  ------------------ ---------------- ----------------- ------------------
  **Competition      **\# of FTE**    **FTE Change**    **Maximum Length
  Type**                                                of
                                                        Implementation**

  As-Is Organization Any              Any               2 months

  Streamlined with   Any              Any               6 months
  MEO                                                   

  Standard           Any              Any               6 to 12 months
  ------------------ ---------------- ----------------- ------------------

While the above table shows the maximum time an implementation can take,
the implementation efforts may require less time. The greater the change
from the "as-is" or current organization, the longer the Implementation
Period may need to be; however, if the change is minimal, the
implementation time may not need to be the full time allotted.
Deviations from this policy must be presented to the CASC for
recommendation for approval by the DDM. Use the table above and the
requirements of the PWS/RD to choose a Stand-Up date when putting
together Implementation Schedules.

### Implementation of the IHSP

The following describes the activities required during the
Implementation Period. As mentioned, each major section includes a flow
chart to outline and clarify the steps. Each Implementation effort will
vary to some degree; however, there are specific items and tasks the
Team must address. In addition to the detailed descriptions contained in
this Section, there is also a checklist to assist the Responsible
Official and Implementation Team in determining responsibilities and
priorities in Exhibit G-4.

#### IHSP Kickoff Meeting

Figure G-6

![](media/image2.wmf)

The IHSP Kickoff Meeting is organized and run by the Contracting Officer
and is designed to facilitate the start of the implementation of the
IHSP.

The Contracting Officer should invite the following individuals to the
Kickoff Meeting:

-   Responsible Official

-   Project Officer

-   IHSP Manager (or highest level supervisor)

-   CART Representative

-   Human Resources Advisor/Transition Center Representative

The following agenda is recommended for the IHSP Kickoff Meeting;
however, the Contracting Officer may customize the agenda as needed.

+-----+----------------------------------------------------------------+
| **I |                                                                |
| HSP |                                                                |
| K   |                                                                |
| ick |                                                                |
| off |                                                                |
| Mee |                                                                |
| tin |                                                                |
| g** |                                                                |
|     |                                                                |
| *   |                                                                |
| *Ag |                                                                |
| end |                                                                |
| a** |                                                                |
+-----+----------------------------------------------------------------+
| 1\. |                                                                |
| Let |                                                                |
| ter |                                                                |
| of  |                                                                |
| O   |                                                                |
| bli |                                                                |
| gat |                                                                |
| ion |                                                                |
| Rev |                                                                |
| iew |                                                                |
| and |                                                                |
| Sig |                                                                |
| nat |                                                                |
| ure |                                                                |
+-----+----------------------------------------------------------------+
| 2\. |                                                                |
| Ro  |                                                                |
| les |                                                                |
| and |                                                                |
| R   |                                                                |
| esp |                                                                |
| ons |                                                                |
| ibi |                                                                |
| lit |                                                                |
| ies |                                                                |
+-----+----------------------------------------------------------------+
| 3\. |                                                                |
| Pe  |                                                                |
| rfo |                                                                |
| rma |                                                                |
| nce |                                                                |
| M   |                                                                |
| oni |                                                                |
| tor |                                                                |
| ing |                                                                |
+-----+----------------------------------------------------------------+
|     | a\. Cost Monitoring                                            |
+-----+----------------------------------------------------------------+
|     | b\. Quality Assurance                                          |
+-----+----------------------------------------------------------------+
|     | c\. Reporting Requirements                                     |
+-----+----------------------------------------------------------------+
| 4\. |                                                                |
| M   |                                                                |
| odi |                                                                |
| fic |                                                                |
| ati |                                                                |
| ons |                                                                |
| and |                                                                |
| D   |                                                                |
| evi |                                                                |
| ati |                                                                |
| ons |                                                                |
+-----+----------------------------------------------------------------+
|     | a\. Requirements-Driven Changes                                |
+-----+----------------------------------------------------------------+
|     | b\. Resource-Driven Changes                                    |
+-----+----------------------------------------------------------------+
|     | c\. Key Personnel Changes                                      |
+-----+----------------------------------------------------------------+
| 5\. |                                                                |
| Im  |                                                                |
| ple |                                                                |
| men |                                                                |
| tat |                                                                |
| ion |                                                                |
| E   |                                                                |
| ffo |                                                                |
| rts |                                                                |
+-----+----------------------------------------------------------------+
|     | a\. Implementation Team Members                                |
+-----+----------------------------------------------------------------+
|     | b\. Required Stand-Up Date                                     |
+-----+----------------------------------------------------------------+
|     | c\. Schedules and Milestones                                   |
+-----+----------------------------------------------------------------+
|     | d\. Implementation Checklist                                   |
+-----+----------------------------------------------------------------+
|     | e\. Change to Organizational Structures, Roles, and            |
|     | Responsibilities                                               |
+-----+----------------------------------------------------------------+

Kickoff meetings will normally occur 14 days (10 business days) after a
performance decision. During that time, employees are notified of the
decision, public announcement of the decision occurs, the Letter of
Obligation is developed and approved, debriefings are held, and
information regarding the decision is made available to the public upon
request. In a standard competition, the kickoff may be delayed by a
protest or appeal process. See Exhibit G-9 for the template schedule of
events between a performance decision and the kickoff meeting. See
Section C.12 and Section D.5 for additional detail regarding the
performance decision. See Section F for additional information regarding
notifications and announcements.

One of the most important activities at the meeting is the review of the
Letter of Obligation and the signing of the Letter of Obligation by the
Responsible Official and Contracting Officer. The Letter of Obligation
obligates the IHSP to perform the work in the PWS/RD, which is why this
task is important. Additional information on preparing, issuing, and
signing the Letter of Obligation is included below.

The meeting attendees should review the roles and responsibilities of
personnel involved in the Implementation Process as well as the
responsibilities and goals of the implementation effort. There is
typically an Implementation Team assembled to assist the Responsible
Official with Implementation activities. While the Team's attendance is
not needed at the Kickoff Meeting, outlining their roles and
responsibilities is part of the agenda.

Another task for the Kickoff Meeting is to review the performance
monitoring requirements, the modification and deviation processes, and
the cost reporting requirement. All of these are discussed in more
detail in Chapter H.

The following is a check list of the materials needed for the Kickoff
Meeting. Make sure to have a copy for each of the attendees and make
three record copies of the Letter of Obligation.

-   Letter of Obligation with any applicable attachments

-   Schedule templates

-   Implementation checklist

-   Study documents

-   Report templates

-   Cost monitoring forms and instructions

-   Modification and deviation forms and instructions

##### The Letter of Obligation

For in-house performance decisions, the organization implemented is
referred to as the IHSP. Typically, this is the MEO as developed and
proposed in Agency Tender. In other cases, the IHSP will be an as-is
organization. Even though it is an in-house win, one can be assured
things will be at least slightly different than they were before the
performance decision. This is primarily because the organization is now
considered an IHSP, and is therefore accountable to the Government. This
accountability is formally established with the Letter of Obligation.
The Letter of Obligation is the formal agreement between the IHSP and
the contracting office regarding the work requirements that were the
basis for the competition.

##### Prepare and Issue the Letter of Obligation (Contracting Officer)

The official responsible for the preparation and issuance of a Letter of
Obligation is a Contracting Officer from the Office of Logistics and
Acquisition Operations (OLAO). The CONTRACTING OFFICER must make sure
the Letter of Obligation is issued, fully signed, and accepted,
following the official contest period after the Award. It is recommended
this be completed as part of the IHSP Kickoff Meeting. A sample schedule
for completing this activity is provided in Exhibit G-9 for both
decisions with and without protest. The sample schedule also outlines
who is responsible for carrying out the steps.

NIH has developed two templates for use when preparing a Letter of
Obligation; one for Standard Competitions and another for Streamlined
Competitions. These templates are provided in [G.5.1.1Exhibit
G-1]{.mark} and [G.5.1.1Exhibit G-2]{.mark}. The templates developed are
applicable for virtually any in-house decision, but the Contracting
Officer will customize them to meet the needs and requirements of each
particular organization.

The Letter of Obligation should include a summary of the functional
requirements (e.g., PWS or RD), the period of performance, estimated
costs, reporting requirements, inspections and monitoring of services,
and any other special requirements. While not all of these items are
required, this is the official and formal agreement that binds the IHSP
to perform the work, so it is important to be clear in describing their
obligations.

Other sections of this guidebook outline in more detail the
responsibilities of the Contracting Officer, including authorizing
amendments to the Letter of Obligation in order to accommodate workload
changes, or other work environment issues that may change the scope of
the requirements to be performed.

##### Sign the Letter of Obligation (Responsible Official)

The Letter of Obligation is signed by the individual who is responsible
for the performance of the work and requirements in the RD or PWS. The
Deputy Director for Management appoints the Responsible Official during
preliminary planning. The Circular requires that the Letter of
Obligation be issued to an official responsible for performing the
commercial activity. Thus, the person who signs the Letter of Obligation
is normally in the management chain above the MEO.

The official who signs the Letter of Obligation is accountable to NIH
management for the organization's performance. This accountability lasts
for the entire term of performance, and this responsibility can be
re-delegated as necessary.

Before identifying the Responsible Official, the Contracting Officer and
Project Officer should review the potential organizational or management
scenarios. The CART will check all appointments prior to their approval
to ensure that the appointments follow NIH policy for conflicts of
interest.

Scenario 1: One Function -- One Organization

> When the function competed is a well defined, cohesive business unit,
> organizationally structured and consistent with the commercial
> activity performed, it is relatively simple to determine the
> Responsible Official. Typically, the Director of the organization
> becomes the Project Officer and his or her deputy becomes the
> Responsible Official. For example, a motor pool is a business unit
> that supports an entire activity, with a Director, a clear
> organizational structure to perform the mission, and all employees
> ultimately responsible to a Motor Pool Director. In this example, the
> Motor Pool Director would be the Project Officer and his or her deputy
> would be the Responsible Official and would sign the Letter of
> Obligation. In a very small organization or study, it may be difficult
> to identify two personnel with detailed knowledge of the function. In
> this case, the organization may request that a higher-level manager or
> a peer supervisor serve as the Project Officer.

Scenario 2: Multi-Function -- One Organization

> If more than one function within a larger organizational component was
> competed, the scenario is a little more complex, but generally not
> difficult to address. While there may be multiple activities or
> functions, and potentially a direct supervisor for each, the
> supervisors and their respective functional areas of performance are
> still part of a larger mission or functionally cohesive unit.
> Therefore, the employees in the organization are ultimately
> accountable to one manager or supervisor at a higher level in the
> organization. That manager or supervisor may serve as the Project
> Officer, with his or her deputy, or a lower-level manager who
> supervises part or all of the MEO, serving as the Responsible
> Official. For example, a competition may be conducted for the Training
> and IT support functions within one IC. Both the Training and IT
> groups have their own supervisors, who are responsible to a manager or
> supervisor at the next level. The higher-level manager serves as the
> Project Officer while the IT group, which has two-thirds of the FTE
> within the MEO, serves as the Responsible Official.

Scenario 3: One or Multi-Function -- Multi-Organization

> For competitions where functions cross operationally divergent
> organizational boundaries, the scenario is more complicated. For
> example, a competition of administrative functions across multiple ICs
> would include multiple supervisors and managers accountable for the
> performance of the activity. This can make it difficult to determine
> who the Responsible Official should be.
>
> In this situation, the Preliminary Planning Team may identify multiple
> potential Responsible Officials and Project Officers. They submit the
> identifications through the CASC for final approval by the DDM. In
> some cases, the CASC will help identify an appropriate and qualified
> Responsible Official and Project Officer.
>
> In all determinations of the personnel who will serve in the above
> roles, it is important to keep in mind the complex and potentially
> time-consuming interrelationships that are associated with
> post-competition implementation and oversight. Section G.2 provides
> details regarding the relationships that occur in each scenario, and
> should be reviewed prior to determining the final structure of the
> Letter of Obligation administration and oversight functions.

#### Select the Implementation Team

##### Implementation Team Leader 

The Responsible Official serves as the Implementation Team Leader,
unless the Deputy Director for Management approves a delegation of this
role. The Implementation Team Leader ensures that the necessary
milestones are met and everything moves as smoothly as possible during
Implementation. In general, the Team Leader will oversee all
Implementation activities, make decisions, delegate tasks to the
Implementation Team, and make sure the IHSP organization meets the
Stand-Up date. The Implementation Team Leader is also responsible for
organizing meetings, making decisions, and managing the Post Competition
activities, which continue after the Stand-Up of the organization. A
significant amount of effort is required of the Implementation Team
Leader prior to stand up; however, while the level of effort may
decrease after Stand-Up, the individual will have an obligation to the
organization. It is important for the person selected as the
Implementation Team Lead to understand the level of effort and
responsibility associated with this position.

##### Implementation Team Members (identified by the Responsible Official with notification to the Deputy Director for Management)

To effectively complete the implementation activities, the
Implementation Team Leader will need the assistance of a knowledgeable
Team. The purpose of the Implementation Team is to provide leadership,
guidance, and decisions throughout the implementation process; most
importantly, they are vital to minimizing the effect the implementation
has on the products and services of the organization. The Team should
include members with a variety of expertise and skills in the functional
area and business unit, as well as human resources and personnel
management. This expertise will help ensure a successful, thoughtful,
and positive transition to the IHSP.

The invitation to participate on the Implementation Team should be
extended to all ICs with affected employees, and identification and
approval of Implementation Team members should follow the process
outlined in G.3.2.1.3.

Some or all of the members of the Implementation Team may have been
identified or chosen before the performance award date (as suggested in
[Section B](#_Preliminary_Planning)); if not, the Team should be
identified as soon as possible after the Letter of Obligation is signed.
Potential team members can be identified during the initial Kickoff
Meeting, and typically membership should be finalized within a few weeks
of the signing of the Letter of Obligation. Forming the Team quickly is
particularly important when the Implementation period is short (e.g.,
two months).

The following is a list of typical Implementation Team Members,
including a brief description of what their role on the Team is, and why
they may be needed. This list should serve only as a guide, and the
Project Officer or MEO Manager may customize the membership of the Team
to fit the needs specific to the IHSP's organization. The Implementation
Team may have individuals with expertise in only one area, or whose
expertise crosses several areas. Furthermore, the Team is not limited to
one person per area or expertise, with the sized of the Team dependent
on the size of the competition. Fill in the following table as the
Implementation Team is selected.

Implementation Team Members

+------------------+------------------+-------------------------------+
|                  | *Human Resources | The Human Resources Advisor   |
|                  | Advisor          | is necessary to ensure all    |
|                  | (required        | personnel actions are handled |
|                  | member)*         | appropriately and applicable  |
|                  |                  | deadlines and timeframes are  |
|                  |                  | met. The Human Resources      |
|                  |                  | Advisor should already be     |
|                  |                  | identified and will have      |
|                  |                  | participated in the other     |
|                  |                  | phases of the competition     |
|                  |                  | process. The Human Resources  |
|                  |                  | Advisor is responsible for    |
|                  |                  | identifying and coordinating  |
|                  |                  | transition services.          |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Implementation  | The Implementation Team       |
|                  | Team Leader      | Leader heads the              |
|                  | (required        | implementation effort. Often, |
|                  | member)*         | the Implementation Team       |
|                  |                  | Leader is the Responsible     |
|                  |                  | Official or former ATO.       |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *CART            | The CART Representative is    |
|                  | Representative   | assigned to the               |
|                  | (required        | Implementation Team by the    |
|                  | member)*         | Office of Management          |
|                  |                  | Assessment (OMA). This        |
|                  |                  | individual will be able to    |
|                  |                  | provide guidance on NIH       |
|                  |                  | policies and procedures for   |
|                  |                  | the implementation and        |
|                  |                  | post-competition efforts.     |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Communications  | The Communications            |
|                  | Coordinator*     | Coordinator has skills and    |
|                  |                  | knowledge associated with     |
|                  |                  | contacting and providing      |
|                  |                  | information to affected       |
|                  |                  | personnel and the NIH         |
|                  |                  | community. The need for a     |
|                  |                  | dedicated individual will be  |
|                  |                  | dependent on the size of the  |
|                  |                  | organization and the level of |
|                  |                  | communication expected.       |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *NIH and/or      | Management is a valuable      |
|                  | Division         | resource for knowledge of the |
|                  | Management*      | organization, process, and    |
|                  |                  | employees. Having the         |
|                  |                  | cooperation and understanding |
|                  |                  | of Management will ease the   |
|                  |                  | implementation process. These |
|                  |                  | individuals may be management |
|                  |                  | representatives from the      |
|                  |                  | affected ICs.                 |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Subject Matter  | Subject matter experts are    |
|                  | Experts*         | beneficial when it comes to   |
|                  |                  | implementing changes          |
|                  |                  | identified in the MEO or      |
|                  |                  | private sector offer and      |
|                  |                  | maintaining the continuity of |
|                  |                  | operations during the         |
|                  |                  | implementation. Depending on  |
|                  |                  | the function, there may be a  |
|                  |                  | need for several subject      |
|                  |                  | matter experts. These         |
|                  |                  | individuals may be            |
|                  |                  | representatives from the      |
|                  |                  | affected ICs.                 |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Information     | Including an individual       |
|                  | Technology       | familiar with IT on the Team  |
|                  | Resource*        | is particularly helpful if    |
|                  |                  | there are new technology      |
|                  |                  | requirements or systems, or a |
|                  |                  | large turnover of employees   |
|                  |                  | is anticipated during the     |
|                  |                  | implementation. The need for  |
|                  |                  | this individual is dependent  |
|                  |                  | on the IHSP organization and  |
|                  |                  | technological changes.        |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Administrative  | AOs are responsible for tasks |
|                  | Officer (AO)*    | such as timekeeping, ID       |
|                  |                  | badges, finance and budget,   |
|                  |                  | space and overall IC          |
|                  |                  | operations. New or exiting    |
|                  |                  | employees and changes in      |
|                  |                  | location or facilities will   |
|                  |                  | require coordination with     |
|                  |                  | these individuals. Having an  |
|                  |                  | AO representative familiar    |
|                  |                  | with the process as part of   |
|                  |                  | the Team might be beneficial  |
|                  |                  | especially if there are       |
|                  |                  | multiple locations and        |
|                  |                  | changes.                      |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Union           | If there are affected         |
|                  | Representative*  | employees who are in the      |
|                  |                  | Union, it is highly           |
|                  |                  | recommended that a Union      |
|                  |                  | Representative be on the      |
|                  |                  | team. The level of            |
|                  |                  | participation for the Union   |
|                  |                  | Representative will vary      |
|                  |                  | depending on the interest and |
|                  |                  | number of employees affected. |
|                  |                  | Regardless, the invitation to |
|                  |                  | join the Implementation Team  |
|                  |                  | should be extended to the     |
|                  |                  | Union when Union employees    |
|                  |                  | are involved.                 |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *A-76 Consultant | While not required, having    |
|                  | or Expert*       | someone who is familiar with  |
|                  |                  | the A-76 and implementation   |
|                  |                  | processes is very beneficial. |
|                  |                  | The CART representative will  |
|                  |                  | be able to identify possible  |
|                  |                  | consultant support or A-76    |
|                  |                  | expertise available to the    |
|                  |                  | Team.                         |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  |                  |                               |
+------------------+------------------+-------------------------------+
|                  | *Other Team      | Expertise/IC:                 |
|                  | Members*         |                               |
|                  |                  |                               |
|                  | *(Identify as    |                               |
|                  | needed)*         |                               |
+------------------+------------------+-------------------------------+
|                  |                  | Expertise/IC:                 |
+------------------+------------------+-------------------------------+
|                  |                  | Expertise/IC:                 |
+------------------+------------------+-------------------------------+
|                  |                  | Expertise/IC:                 |
+------------------+------------------+-------------------------------+

After selecting the Team, the Team Leader should schedule an initial
team meeting to discuss the Implementation process, responsibilities,
and schedule. It is recommended the Team pick a time and a place for
standing meetings and determine the best and most effective way to
communicate amongst the Team members. These meetings may continue even
after the IHSP is implemented to track progress changes and reporting.
Taking minutes at the meetings will help to ensure everyone is aware of
progress and assigned responsibilities.

#### The Implementation Schedule

##### Identify Milestones (Project Officer and Team Leader)

The milestones for the Implementation Team are the main activities the
Team must complete between the Award and Stand-Up date. The CART and
Contracting Officer may provide specific or approximate dates, but the
milestones should be set during the Implementation Kickoff Meeting.

The milestones are also the dates the CART is interested in for
reporting purposes, specifically for OMB. Therefore, the Implementation
Team Leader must maintain the schedule of milestones included in Exhibit
G-5 and submit an updated version weekly to the CART during the
Implementation Period.

The following table will help identify the structure and timeframe for
Implementation during the Kickoff meeting.

+-----------------------------------------------+----------------------+
| **Milestone**                                 | **Date**             |
+-----------------------------------------------+----------------------+
| 1.  Performance Award Decision                |                      |
+-----------------------------------------------+----------------------+
| 2.  Award Announcement                        |                      |
+-----------------------------------------------+----------------------+
| 3.  Signing of Letter of Obligation (Kickoff  |                      |
|     Meeting)                                  |                      |
+-----------------------------------------------+----------------------+
| 4.  Implementation Start                      |                      |
+-----------------------------------------------+----------------------+
| 5.  Stand-Up                                  |                      |
+-----------------------------------------------+----------------------+

The Implementation Team should schedule the Stand-Up date to coincide
with a pay period. This may seem minor; however, it is very beneficial
when coordinating the human resources activities.

If the projected Stand-Up date differs from the date originally
projected for Stand-Up, the Implementation Team Lead must provide a
writing justification to the Contracting Officer and the CART. IHSPs are
to be treated as contracts, and a change to Stand-Up is a significant
event in a contract.

##### Set the Schedule (Implementation Team)

The Implementation process requires multiple steps to meet the
milestones listed above. To ensure the tasks described within this
chapter are completed prior to Stand-Up, it is beneficial to develop a
detailed schedule. This schedule is internal to the Implementation Team
and is designed to be customized to meet the needs of the Team and the
Implementation efforts. The Team will most likely have a better
understanding of how long the tasks will take once they are familiar
with the requirements. Therefore, the Team should read this Chapter in
its entirety prior to determining the schedule.

To help the Team plan accordingly, a sample detailed schedule is
included in Exhibit G. This schedule is designed to be customized by the
Team and used as needed. The following table may also help the Team plan
some of the internal deadlines.

  ------------------------------------------------ ----------------------
  **Task**                                         **Date**

  Implementation Start                             

  Review Key Documents                             

  Develop Communication Strategy                   

  Develop Employee Transition Plan                 

  VERA/VSIP Request                                

  Begin Staffing                                   

  Establish CGA                                    

  Implement QA and Cost Monitoring Procedures      

  Training                                         

  Stand Up                                         
  ------------------------------------------------ ----------------------

In some situations, a Phase-In Plan may have been developed during the
competition process. The Team can use the general schedule typically
included in the Phase-In Plan as a basis for the actual schedule to be
developed. However, it likely will need to be updated and further
developed.

Generally, the Implementation Team must complete their activities within
the maximum time allowed. It may become apparent during schedule
development that additional time is needed to complete implementation.
If this occurs, the Implementation Team must request an extension from
the Contracting Officer. This may be necessary if the identified
activities cannot be completed within the timeframe specified when the
Stand-Up date was decided. For example, if there are many affected
employees who must be placed, the Implementation may need more time to
place all of them. Allowing sufficient time to complete the key tasks is
essential to a smooth transition. However, it is also important and good
practice not to let the transition take any longer than necessary
because of the disruption the process can cause with affected personnel
and customers.

#### Read the Key Documents (Implementation Team)

Another important step the Team should take is to review the key
documents of the competition. This includes the PWS or RD, MEO, the
Agency Tender, Phase-In Plan, Quality Control (QC) Plan, Quality
Assurance Surveillance Plan (QASP), and Cost Estimates. Not all of these
may be applicable to every competition, but the Team should identify and
obtain all applicable key documents.

As part of the review, the Team should identify discrepancies or changes
in the documents that need to be discussed or addressed. For example,
there may be changes in workload or revised performance periods. The
Team Leader may coordinate with the CART and Contracting Officer to
obtain copies of the competition documents for the Team. The following
table shows they typical documents for each type of competition.

  --------------------------------------- ----------------- ---------------
  **Documents**                           **Streamlined**   **Standard**

  PWS                                                       X

  RD                                      X                 

  MEO                                     X                 X

  Agency Tender                           X                 X

  Phase-In Plan                           \*                X

  Quality Control Plan                    X                 X

  Quality Assurance Surveillance Plan     X                 X

  Cost Estimates                          X                 X

  Letter of Obligation                    X                 X
  --------------------------------------- ----------------- ---------------

\* Some streamlined competitions may have Phase-In-Plans.

The key documents are important as they identify the information that
needs to be tracked and measured and help in determining the time-frame
for implementation, interim steps and deadlines, and the responsibility
of the IHSP. In addition, the documents will assist the Team in
understanding the new organization by becoming familiar with the
requirements, procedures, and organizational structure.

The Team should review the documents to determine if there are changes
that occurred between the development of the PWS/RD and Award. Also, the
Team should examine how the current organization and the MEO are
different and the level of effort it will take to make the change.

The Team must identify where the IHSP has proposed new policies,
procedures, and equipment beyond what is described in the PWS or RD.
Even if there are minimal changes, all changes should be identified to
ensure the continuity of services and to inform all affected parties.
New equipment, procedures, and policy may have been developed or
implemented since the development of the PWS/RD and Agency Tender, and,
therefore, may affect the Stand-Up of the organization.

For example, the IHSP may have proposed using an electronic system to
track workload, which eliminates some of the manual steps to log work.
As a result, there may be processes in the organization that may need to
be modified. This change may also lead to new training requirements.

The IHSP's Agency Tender/MEO should be released to the affected
employees at the time of the Implementation start; however,
Implementation Team Members may wish to acquire a copy of the Agency
Tender/MEO prior to the first Implementation Meeting from the
Contracting Officer. This will help if the Team members interact with
affected employees who may have questions when the documents are
released publicly.

The Team should also review the PWS, RD, or solicitation for additional
plan requirements (e.g., Continuity of Operations Plan (COOP)). The Team
must identify what plans and other requirements for which they are
responsible. Again, not every Implementation is the same, and therefore,
there may be some tasks that do not apply.

The Team may want to use the following checklist when reviewing the key
documents to track changes, needs, and potential issues.

**Document Review Checklist**

+---------------------------------+----+----+-------------------------+
| **CHANGE or NEED**              | *  | ** | **NOTES**               |
|                                 | *Y | NO |                         |
|                                 | ES | ** |                         |
|                                 | ** |    |                         |
+---------------------------------+----+----+-------------------------+
| ***PWS/RD Changes***            |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Regulations and Directives      |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Services and Workload           |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Performance Standards           |    |    |                         |
+---------------------------------+----+----+-------------------------+
| > Quality                       |    |    |                         |
+---------------------------------+----+----+-------------------------+
| > Timeliness                    |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Work Locations                  |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Customers                       |    |    |                         |
+---------------------------------+----+----+-------------------------+
| ***MEO Changes***               |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Staffing                        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Processes and Procedures        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Automated system for tracking   |    |    |                         |
| workload                        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Training                        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Non-furnished equipment and     |    |    |                         |
| property                        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Quality Control Program         |    |    |                         |
+---------------------------------+----+----+-------------------------+
| ***Agency Cost Estimate         |    |    |                         |
| Changes***                      |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Performance Periods             |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Staffing                        |    |    |                         |
+---------------------------------+----+----+-------------------------+
| Equipment and property          |    |    |                         |
+---------------------------------+----+----+-------------------------+
| ***Quality Assurance/Quality    |    |    |                         |
| Control Needs***                |    |    |                         |
+---------------------------------+----+----+-------------------------+
| System for measuring the        |    |    |                         |
| performance of the organization |    |    |                         |
+---------------------------------+----+----+-------------------------+

The Chart above will help the Team process the information as they read
and identify any factors that may affect the implementation process or
the performance of the IHSP. This will also help the Team identify where
more information is needed and determine how to get the information. The
Team should document any changes for potential modifications and
deviations and notify the appropriate individuals and groups (e.g.,
Contracting Officer, CART, CASC) of the issues and concerns that are
identified.

The review of documents should be complete early in the Implementation
process. These documents provide the basis for the IHSP's organization
and responsibilities, and are the primary source of information for the
Implementation Team.

#### Staff the IHSP Organization (Human Resources Advisor, Implementation Team)

Staffing the organization is a critical step in "standing-up" the IHSP's
organization. Potentially, the Implementation Team may encounter changes
in structure, quantity of employees, and grades. The following steps
will help the Implementation Team identify the staffing activities
needed, and meet the Stand-Up deadline.

Figure G-7

![](media/image3.wmf)

***Develop an Employee Transition Plan (Human Resources Advisor,
Transition Center Representative)***

The Human Resources Advisor is responsible for developing and preparing
an Employee Transition Plan for the organization. The Employee
Transition Plan should normally be prepared during development of the
MEO. The Plan is reviewed and refined by the Implementation Team and
must be approved by the Deputy Director for Management (DDM). The
Employee Transition Plan addresses the changes between the current
organization and the Service Provider's organization. For an IHSP win,
this may also involve plans for VERA/VSIP and the Transition Center, as
well as the use of directed reassignments, recruitment, and change to
lower grade.

The Human Resources Advisor will follow NIH goals and guidance to ensure
employees are fairly placed into new or existing organizations, while
taking into consideration the competencies of the employee. The NIH
Staffing Principles are provided in Exhibit G-6.

The following outlines the content of an Employee Transition Plan:

> **[Introduction]{.underline}**: The introduction provides a synopsis
> of the MEO. Indicating the function that was studied, how the review
> was accomplished, a snapshot of the resulting organization, as well as
> the outcome and impact on the population.
>
> **[Directed Reassignments]{.underline}**: The Human Resources Advisor,
> in coordination with the servicing HR Specialist, will identify all
> possible direct reassignments within the impacted population to reduce
> the amount of resources and time required to staff the organization.
> Names, current titles, series and grades should be listed (even though
> they are not in the sample below).
>
> **[Recruitment]{.underline}**: The Human Resources Advisor will
> identify, in coordination with the servicing HR Specialist, the
> recruitment actions that will be required to complete the staffing of
> the MEO. The process to be followed and areas of consideration outside
> of the impacted population will be identified.
>
> **[Retirement Options and Buyouts]{.underline}**: This should indicate
> whether this authority will be pursued, and the status of the request,
> and whether/hoe notification has been provided to the impacted staff.
>
> **[Current Staff]{.underline}**: This should indicate what may be
> required of current staff in order to be placed, as well as special
> circumstances that may exempt current staff from some of the efforts
> identified above.
>
> **[Implementation Team]{.underline}**: The approved Implementation
> Team should be listed here. If the team does not reflect full
> representation, such as an impacted IC has chosen not to send a
> representative, then that should be stated here.

Once completed, the HR submits the Employee Transition Plan to the DDM.

***Services Available Through the Transition Center***

The NIH Transition Center was established to assist employees affected
by organizational changes resulting from A-76 competitions, via a
comprehensive career transition program. Basic services provided by the
Transition Center help employees find and successfully compete for
available positions. Intensive services support the individual needs of
those employees when placement is less likely.

Training through the Transition Center is provided to employees,
manager, supervisors, and union representatives affected by the process.
Job search skills, resume writing, skills assessment, interview
techniques, stress management, and transition management, are all
examples of basis services provided by the Transition Center. In
situations where the affected employee does not have the skills or
competencies needed to be placed in any available NIH vacancy, more
intensive services and support are provided. The development of these
employees is detailed and defined through individual training plans.

Training may also be provided to meet the demands of the organization
under review, meet its future workforce needs, provide retraining
strategies and plans, and help displaced employees obtain meaningful
employment. These efforts may require the Transition Center to
coordinate with the other appropriate NIH Training entities.

The Implementation Team should be familiar with the services of the
Transition Center. The Transition Center is not an actual location or
space where employees go to look for jobs; however, the Center is a
source of resources and services to assist employees displaced from
their positions.

***Place Employees in the IHSP Organization***

Once the Employee Transition Plan is approved, the Implementation Team
can begin to work together with the Human Resources Advisor to handle
recruiting, hiring, and staffing of the organization. However, the Team
should work to minimize disruption to the current employees and
customers.

As IHSP positions are filled during the Implementation period, the
Implementation Staffing Status Form must be completed and submitted
twice per month (2nd and 4th Mondays) to the Contracting Officer. This
form should be submitted throughout the Implementation Period until
Stand-Up, following the defined approval chain. This Form will help the
Implementation Team track the progress of the staffing efforts
internally, as well as begin gathering information on the actual staff
composition of the IHSP. A copy of the Implementation Staffing Status
Form is provided in Exhibit G-8.

***Completing the Form***

The Implementation Staffing Status Form has two sections: the left-hand
section listing the positions identified in the Agency Tender and Agency
Cost Estimate and the right-hand section for actual staffing
information. The actual staffing information includes the Current
Employee Name, Position Title, Position Type, Location, Grade, and
Organization at the section level, IC, and FTE amount. The actual
staffing information should be included on the same line as the Agency
Tender/Cost Estimate position on the left. If an IHSP employee does not
correlate to an Agency Tender/Cost Estimate position listed in the
left-hand section of the form, the employee information should be added
in a blank line. It may be helpful or necessary to add a comment for
lines where there is a discrepancy between the Agency Tender and IHSP
Staffing.

The Human Resources Advisor will pre-populate the left side of the form
using the staffing information provided in the Agency Tender. The Human
Resources Advisor, Project Officer, and MEO Manager should monitor the
staffing of the IHSP using this Form. As the Stand-Up date approaches,
it is recommended that the Form be completed and reviewed weekly.

The purposes for completing this form are to establish the exact
positions in the organization, keep the organization on schedule, and to
identify any deviations (even if just administrative; for example, a
change in the position title) to the MEO.

When the staffing is completed, the Project Officer must submit the
completed and final Form to the Contracting Officer for documentation
and filing in the official contract file. This information will also be
used to recode positions in the FAIR Act Inventory. The information
gathered on this form will be directly applied to the Personnel Cost
Tracking forms discussed in Section H.

If the IHSP has vacancies that cannot be filled prior to Stand-Up, or
immediately thereafter, the IHSP may choose to utilize temporary
contractors to fill these vacancies. Since the Circular specifically
prohibits direct conversions to contract without a competition, the IHSP
cannot place contractors permanently in those positions unless they were
proposed as a subcontract. Instead, the IHSP may use temporary
contractors to fill vacancies, and the cost of those subcontracts will
be included in their cost reporting. However, the IHSP should work to
fill those positions with Government FTE as soon as possible.

***Align IHSP Staff in FAIR Act Inventory***

The IC, in coordination with the CART, must align IHSP staff with the
FAIR Act Inventory. This is an important step in the competition process
because NIH must report their Inventory annually. Therefore, it is
imperative to keep this data up-to-date.

#### Communicate With Affected Individuals and Groups (Implementation Team)

Keeping employees, customers, and other affected personnel (directly and
indirectly) informed is crucial to a successful decision implementation
and phase-in.

Since it is important to keep people informed, the Implementation Team
should identify or develop a communications strategy and Communications
Plan.

The Communications Plan or strategy should address how to communicate
with affected staff, customers, NIH leadership, and the overall NIH
community. The Team must identify and designate the lines of
communication between the MEO Manager, Project Officer, and Contracting
Officer within the structures required by the A-76 process and discussed
in Section G.2. For Standard Competitions, a Communications Plan may
have already been included as part of the Agency Tender. A sample
Communications Plan is provided in Exhibit G-3.

Communications should be primarily directed at two different audiences:
the affected staff and the customers who will be receiving the services
of the organization. The Team should keep both audiences aware and
informed of timelines and changes in operations ahead of time. Even if
the only information to share is that there are no new developments or
changes, communication is necessary and may alleviate tension with the
affected individuals and groups. Providing opportunities throughout the
implementation period for both audiences to ask questions and provide
feedback will also help in keeping the communication lines open.

The Team should consider a variety of communication methods, including
meetings, e-mail, and accessible information via the NIH Portal or
Web-site. The Team may also consider holding an all-hands meeting after
the performance decision for affected employees. This meeting may
address the A-76 process, the new organization, and resources available
to affected staff. The Team should compile a list of Frequently Asked
Questions (FAQ) based on the questions asked by the employees to post on
the web or make available via other means, especially for those who were
unable to attend the meeting. The CART maintains a broader FAQ on its
website; see <http://a-76.nih.gov/>.

#### Identify Training Needs and Strategies (Implementation Team)

The Implementation team should identify training needs and opportunities
both before and after Stand-Up. In many scenarios, employees will need
training both before and after Stand-Up. Training needs are often
dependent on the Employee Transition Plan and the differences between
the current organization and the one being implemented. More training
will be needed if new hires are anticipated, duties and responsibilities
change, or other changes from the existing organization and processes.

The Team can identify if there is a current training plan in place for
the organization, ask the IC representatives and supervisors how new
staff are usually trained, and collect information on any existing
standard operating procedures. The functions of the new organization
will typically be the same, and therefore, obtaining historical training
information from the affected organization will most likely be easier
than developing a whole new training plan. The Implementation Team may
want to consider developing a Training Plan for the organization if one
does not exist, or refining an existing Training Plan to align with the
new organization.

The table below presents a summary of some helpful NIH training
resources:

  ------------ --------------------------------------------------- ----------
  **Training   **Training Components**                             **Cost**
  Resource**                                                       

  NIH Training Learning gateway to agency-specific training,       Free and
  Center       strategic development programs and customized       training
               solutions for you and your organization. Along with fee
               providing a wide array of internal learning         
               opportunities, the NIH Training Center collaborates 
               with learning partners such as the HHS University,  
               CIT Training, and CDC Corporate University.         
               Information on a variety of external training       
               resources is available through the NIH Training     
               Center.                                             

  HHS          HHS U provides common needs training and            Free
  University   development opportunities for HHS staff via         online
               traditional classroom training, online self-study,  training
               development programs, and career counseling.        and
                                                                   training
                                                                   fee

  CIT          The CIT Training Program provided by the Center for None
               Information Technology offers a wide variety of     
               courses and seminars that enable users to make      
               efficient and effective use of computers, networks, 
               and information systems in their work at NIH. The   
               training program is open to NIH employees and to    
               all users of CIT computing facilities. Additional   
               computer courses are available through the [NIH     
               Training                                            
               Center](http://learningsource.od.nih.gov/), [HHS    
               University](http://learning.hhs.gov/), and the [NIH 
               Library](http://nihlibrary.nih.gov/training.htm).   

  Transition   Available only to those individuals affected by an  None
  Center       A-76 competition and those not placed in the        
               resulting organization.                             
  ------------ --------------------------------------------------- ----------

#### Coordinate Logistical Changes (Implementation Team)

The Team will be responsible for coordinating with the applicable AOs to
ensure the logistics for the Implementation and Stand-Up efforts are
carried out and the necessary items are obtained or in place prior to
the Stand-Up date.

Depending on the size of the Implementation, it may be helpful to assign
specific individuals or groups responsibility for particular logistical
changes and actions. This might help things progress on schedule and
alleviate some of the pressure on the Project Officer or Responsible
Official, Contracting Officer, and Implementation Team.

#### Consider Developing Contingency Plans (Implementation Team)

The Implementation Team should consider developing contingency plans to
prepare for the unexpected. For example, delayed start dates or
inability to fill the IHSP positions. These are issues that frequently
arise during the Implementation period and should be addressed by the
Team throughout the process. The Team may want to examine what the
"worst-case" scenarios are in preparation for Stand-Up. Another approach
to consider is using phased or trial roll-outs of new systems and
processes. This will help address any problems on a smaller scale,
thereby limiting the impact on employees and customers.

For instance, a contingency plan for staffing shortages may include the
use of a subcontractor to temporarily fill vacancies until permanent
staff are hired. In a situation where the IHSP is proposing the
development and use of a new technology or system, potential delays and
correction of "bugs" should be addressed. The Implementation Team may
want to include in the Implementation Schedule time for beta-testing of
new systems or procedures with a small portion of employees and
customers before implementing completely. This staggered or phase-in
method would allow time for customer and employee feedback, and the
ability to improve the new process before employing it for the entire
organization and customer population. Processes can also be transitioned
gradually across the organization in sections, as opposed to an
immediate change in operations.

#### Conduct Inventories of Property (Implementation Team)

Although the Team may have already reviewed the PWS or RD, the Team
should review the Government Furnished Property and Government Furnished
Supplies sections again prior to completing inventory requirements.
Normally, the Team will need to coordinate and conduct an inventory of
the on-hand equipment and supplies that will be provided to the IHSP by
the Government. The Team should also check the planned utilization of
Government Furnished Facilities to determine whether any space will need
to be changed or personnel moved to accommodate new IHSP personnel or
processes. The Team will also want to identify equipment or facilities
that need to be repaired or changed before they are officially turned
over to the IHSP. Any changes to facilities or equipment are likely to
involve costs, and as such, should be included in budgets for work
associated with support of the IHSP. In some cases, the IHSP will also
have facilities or equipment that it controls, and these items will also
need to be included in the overall budget for the organization.

### Stand-Up the Organization

The Implementation Period is when the staffing of the organization takes
place, the QASP is revised and prepared for implementation, and the new
organization begins to take shape. During this time, the IHSP may begin
to assume partial responsibility (if they haven't already been doing the
work) for the products and services being provided. The IHSP's
organization also begins to be accountable to the Contracting Officer
and Project Officer.

The Stand-Up of the IHSP is the actual day the organization assumes full
responsibility and performance of the products and services. Ideally,
all positions in the organizations are filled and any changes have been
accomplished by Stand-Up.

In the last few weeks before stand-up, the Project Officer and
Responsible Official or MEO Manager should regularly review the staffing
status, the QASP and QA procedures, and monitor the full transition. The
following is a checklist of potential "last minute" tasks either to
verify status or monitor closely.

-   Transfer of employees to IHSP organizations (change job codes)

-   Post vacancies, review applicants, select staff

-   Finalize internal cost tracking methods

-   Finalize logistical information (locations, phone, IT and NED
    accounts, timekeeper, AO)

On the date of Stand-Up, the employees should all be realigned with the
IHSP organization, and the IHSP will be fully responsible and
accountable for performance.

## Potential Pitfalls

There are several pitfalls those involved with the Implementation
process should be aware of. First, make sure to identify a schedule that
is reasonable. While it is important to make sure the process is not
excessively long, be sure to allow enough time, particularly for the
human resource activities. The requests for VERA/VSIP and the approval
of the Employee Transition Plan are dependent on outside parties, and
therefore, the Team does not have a lot of control over when they are
received.

Next, make sure the invitation to join the Implementation Team is
extended to all ICs with affected employees. While ICs may choose not to
participate, it is very important they be given the opportunity. The ICs
are bound by the decisions of the Team regardless of whether they
participate in the process or not.

Finally, make sure the individuals involved in the process understand
the requirements and responsibilities they are assuming. This is an
important step in the overall A-76 process and the participants need to
understand their roles.

## Exhibits

######### Letter of Obligation for Standard Competition

######### Letter of Obligation for Streamlined Competition

######### NIH CART Sample Communications Plan

######### Decision Implementation and Phase-In Checklist

######### Sample Implementation Schedule Tracking Tool

######### NIH Staffing Principles

######### Key Player Position Summaries

######### Contracting Officer {#contracting-officer .unnumbered}

######### Human Resources Advisor {#human-resources-advisor .unnumbered}

######### Project Officer {#project-officer .unnumbered}

######### Implementation Staffing Status Form

######### Letter of Obligation Schedule

#  {#section .unnumbered}