# Table of contents {#table-of-contents .TOC-1}

# C.1.0 Background [3](#c.1.0-background) {#c.1.0-background-3 .TOC-1}

# C.2.0 Introduction [3](#c.2.0-introduction) {#c.2.0-introduction-3 .TOC-1}

# C.2.1 Scope of Work [5](#c.2.1-scope-of-work) {#c.2.1-scope-of-work-5 .TOC-1}

# C.2.2 Competitive Sourcing Contractor Support Guidelines [6](#c.2.2-competitive-sourcing-contractor-support-guidelines) {#c.2.2-competitive-sourcing-contractor-support-guidelines-6 .TOC-1}

# C.3.0 Description of Tasks [7](#c.3.0-description-of-tasks) {#c.3.0-description-of-tasks-7 .TOC-1}

# C.3.1 Task 1: Competitive Sourcing Program Management Support [7](#c.3.1-task-1-competitive-sourcing-program-management-support) {#c.3.1-task-1-competitive-sourcing-program-management-support-7 .TOC-1}

# C.3.1.1 Sub-task 1.1: Identify Inherently Governmental Positions [7](#c.3.1.1-sub-task-1.1-identify-inherently-governmental-positions) {#c.3.1.1-sub-task-1.1-identify-inherently-governmental-positions-7 .TOC-1}

# C.3.1.2 Sub-task 1.2: Plan Commercial Activities Study [8](#c.3.1.2-sub-task-1.2-plan-commercial-activities-study) {#c.3.1.2-sub-task-1.2-plan-commercial-activities-study-8 .TOC-1}

# C.3.1.2.1 Sub-task 1.2.1: Develop a Communications Plan [8](#c.3.1.2.1-sub-task-1.2.1-develop-a-communications-plan) {#c.3.1.2.1-sub-task-1.2.1-develop-a-communications-plan-8 .TOC-1}

# C.3.1.2.2 Sub-task 1.2.2: Create a CA Team [9](#c.3.1.2.2-sub-task-1.2.2-create-a-ca-team) {#c.3.1.2.2-sub-task-1.2.2-create-a-ca-team-9 .TOC-1}

# C.3.1.2.3 Sub-task 1.2.3: Define the Scope of the A-76 Study [11](#c.3.1.2.3-sub-task-1.2.3-define-the-scope-of-the-a-76-study) {#c.3.1.2.3-sub-task-1.2.3-define-the-scope-of-the-a-76-study-11 .TOC-1}

# C.3.1.2.4 Sub-task 1.2.4: Develop a Training Plan [12](#c.3.1.2.4-sub-task-1.2.4-develop-a-training-plan) {#c.3.1.2.4-sub-task-1.2.4-develop-a-training-plan-12 .TOC-1}

# C.3.1.2.5 Sub-task 1.2.5: Execute Transition Plan [12](#c.3.1.2.5-sub-task-1.2.5-execute-transition-plan) {#c.3.1.2.5-sub-task-1.2.5-execute-transition-plan-12 .TOC-1}

# C.3.2 Task 2: Competitive Sourcing Feasibility/Business Case Analysis [12](#c.3.2-task-2-competitive-sourcing-feasibilitybusiness-case-analysis) {#c.3.2-task-2-competitive-sourcing-feasibilitybusiness-case-analysis-12 .TOC-1}

# C.3.2.1 Sub-task 2.1: Conduct Competitive Sourcing Feasibility Studies [12](#c.3.2.1-sub-task-2.1-conduct-competitive-sourcing-feasibility-studies) {#c.3.2.1-sub-task-2.1-conduct-competitive-sourcing-feasibility-studies-12 .TOC-1}

# C.3.2.2 Sub-task 2.2: Competitive Sourcing Business Case Analysis [13](#c.3.2.2-sub-task-2.2-competitive-sourcing-business-case-analysis) {#c.3.2.2-sub-task-2.2-competitive-sourcing-business-case-analysis-13 .TOC-1}

# C.3.3 Task 3: Develop PWS and QASP Support [13](#c.3.3-task-3-develop-pws-and-qasp-support) {#c.3.3-task-3-develop-pws-and-qasp-support-13 .TOC-1}

# C.3.3.1 Sub-task 3.1: Conduct Market Research [14](#c.3.3.1-sub-task-3.1-conduct-market-research) {#c.3.3.1-sub-task-3.1-conduct-market-research-14 .TOC-1}

# C.3.3.2 Sub-task 3.2: Define Present Operations [14](#c.3.3.2-sub-task-3.2-define-present-operations) {#c.3.3.2-sub-task-3.2-define-present-operations-14 .TOC-1}

# C.3.3.3 Sub-task 3.3: Develop Performance Measures and Standards [15](#c.3.3.3-sub-task-3.3-develop-performance-measures-and-standards) {#c.3.3.3-sub-task-3.3-develop-performance-measures-and-standards-15 .TOC-1}

# C.3.3.4 Sub-task 3.4: Develop the Performance Work Statement (PWS) [15](#c.3.3.4-sub-task-3.4-develop-the-performance-work-statement-pws) {#c.3.3.4-sub-task-3.4-develop-the-performance-work-statement-pws-15 .TOC-1}

# C.3.3.5 Sub-task 3.5: Develop Quality Assurance Surveillance Plan (QASP) [15](#c.3.3.5-sub-task-3.5-develop-quality-assurance-surveillance-plan-qasp) {#c.3.3.5-sub-task-3.5-develop-quality-assurance-surveillance-plan-qasp-15 .TOC-1}

# C.3.3.6 Sub-task 3.6: Obtain Higher Level Review of PWS and QASP [16](#c.3.3.6-sub-task-3.6-obtain-higher-level-review-of-pws-and-qasp) {#c.3.3.6-sub-task-3.6-obtain-higher-level-review-of-pws-and-qasp-16 .TOC-1}

# C.3.4 Task 4: Develop the Management Plan Support [16](#c.3.4-task-4-develop-the-management-plan-support) {#c.3.4-task-4-develop-the-management-plan-support-16 .TOC-1}

# C.3.4.1 Sub-task 4.1: Gather and Analyze Data [17](#c.3.4.1-sub-task-4.1-gather-and-analyze-data) {#c.3.4.1-sub-task-4.1-gather-and-analyze-data-17 .TOC-1}

# C.3.4.2 Sub-task 4.2: Conduct Data Gathering Interviews [17](#c.3.4.2-sub-task-4.2-conduct-data-gathering-interviews) {#c.3.4.2-sub-task-4.2-conduct-data-gathering-interviews-17 .TOC-1}

# C.3.4.4 Sub-task 4.4: Analyze Current Organization [18](#c.3.4.4-sub-task-4.4-analyze-current-organization) {#c.3.4.4-sub-task-4.4-analyze-current-organization-18 .TOC-1}

# C.3.4.5 Sub-task 4.5: Develop the Most Efficient Organization (MEO) [18](#c.3.4.5-sub-task-4.5-develop-the-most-efficient-organization-meo) {#c.3.4.5-sub-task-4.5-develop-the-most-efficient-organization-meo-18 .TOC-1}

# C.3.4.6 Sub-task 4.6: Conduct Mock Reduction-in-Force (RIF) [19](#c.3.4.6-sub-task-4.6-conduct-mock-reduction-in-force-rif) {#c.3.4.6-sub-task-4.6-conduct-mock-reduction-in-force-rif-19 .TOC-1}

# C.3.4.7 Sub-task 4.7: Develop the In-House Cost Estimate (IHCE) [20](#c.3.4.7-sub-task-4.7-develop-the-in-house-cost-estimate-ihce) {#c.3.4.7-sub-task-4.7-develop-the-in-house-cost-estimate-ihce-20 .TOC-1}

# C.3.4.8 Sub-task 4.8: Develop the Technical Performance Plan [20](#c.3.4.8-sub-task-4.8-develop-the-technical-performance-plan) {#c.3.4.8-sub-task-4.8-develop-the-technical-performance-plan-20 .TOC-1}

# C.3.4.9 Sub-task 4.9: Develop the Transition Plan [21](#c.3.4.9-sub-task-4.9-develop-the-transition-plan) {#c.3.4.9-sub-task-4.9-develop-the-transition-plan-21 .TOC-1}

# C.3.5 Task 5: Proposal Evaluation Support [22](#c.3.5-task-5-proposal-evaluation-support) {#c.3.5-task-5-proposal-evaluation-support-22 .TOC-1}

# C.3.6 Task 6: Independent Review Support [22](#c.3.6-task-6-independent-review-support) {#c.3.6-task-6-independent-review-support-22 .TOC-1}

# C.3.6.1 Sub-task 6.1: Review PWS and QASP [22](#c.3.6.1-sub-task-6.1-review-pws-and-qasp) {#c.3.6.1-sub-task-6.1-review-pws-and-qasp-22 .TOC-1}

# C.3.6.2 Sub-task 6.2: Review Management Plan [22](#c.3.6.2-sub-task-6.2-review-management-plan) {#c.3.6.2-sub-task-6.2-review-management-plan-22 .TOC-1}

# C.3.6.3 Sub-task 6.3: Review FAIR Act/A-76 Process [23](#c.3.6.3-sub-task-6.3-review-fair-acta-76-process) {#c.3.6.3-sub-task-6.3-review-fair-acta-76-process-23 .TOC-1}

# C.3.7 Task 7: Post-MEO Performance Review Support [23](#c.3.7-task-7-post-meo-performance-review-support) {#c.3.7-task-7-post-meo-performance-review-support-23 .TOC-1}

**\[USER: Sections A and B will be added by the Contracting Officer upon
award of the Task Order. The term "Statement of Work" or SOW refers to
Sections C through J of the Task Order.\]**

**SECTION C: DESCRIPTION/SPECIFICATIONS/WORK STATEMENT**

# C.1.0 Background

The FAIR Act directs Federal agencies to issue each year an inventory of
all commercial activities performed by Federal employees, e.g., those
activities that are not inherently governmental. OMB is to review each
agency's Commercial Activities Inventory and consult with the agency
regarding its content. Upon the completion of this review and
consultation, the agency must transmit a copy of the inventory to
Congress and make it available to the public. The FAIR Act establishes a
limited administrative appeals process under which an interested party
may challenge the omission or the inclusion of a particular activity on
the inventory as a commercial activity. With completion of the
inventory, including the challenge and appeals process, the FAIR Act
requires agencies to review the activities on the inventory.

OMB issued FAIR Act implementation guidance through revisions to OMB
Circular A-76, "Performance of Commercial Activities," and to its
Supplemental Handbook. OMB Circular A-76 Transmittal Memorandums 20 and
22 provide further guidance, as does the OMB Deputy Director's
Memorandum to Heads of Agencies, dated April 27, 2000. These revisions
inform agencies of the FAIR Act's requirements; implement the statutory
requirements of the FAIR Act; and place the FAIR Act's requirements in
the context of the Federal Government's larger review of its
reinvention, competition and privatization efforts. Copies of these
issuances are found on OMB's Internet Web site at
<http://www.whitehouse.gov/omb/procurement/fair-index.html>*\]* and
paper copies can be obtained from the Office of Federal Procurement
Policy.

# C.2.0 Introduction

This Statement of Work (SOW) defines requirements for The Department of
the Treasury and its bureaus' compliance with the FAIR Act of 1998 and
its implementing guidance contained in OMB Circular No. A-76
(Performance of Commercial Activities). This SOW will present the
framework to enable the Department of the Treasury and its bureaus to
conduct independent A-76 Commercial Activities Studies. The Department
of the Treasury includes 13 bureaus; the following is a list of bureaus
and their headquarters locations:

+-----------------------------------+-----------------------------------+
| **Contact U.S. Treasury\          | **Departmental Offices**\         |
| **1500 Pennsylvania Avenue, NW\   | [Office of Public                 |
| Washington, D.C. 20220\           | Correspondence](http:/            |
| Phone: 202-622-1502\              | /www.treas.gov/opc/opc0005.html)\ |
| Fax: 202-622-6415                 | 1500 Pennsylvania Avenue, NW\     |
|                                   | Washington, D.C. 20220\           |
|                                   | Telephone: 202-622-1502\          |
|                                   | Fax: 202-622-6415                 |
+-----------------------------------+-----------------------------------+
| **CDFI Fund\                      | **OCC**\                          |
| **Department of the Treasury\     | Comptroller of the Currency\      |
| 601 13th Street, NW\              | Washington, DC 20219-0001\        |
| Suite 200-South\                  | Phone: 202-874-5000               |
| Washington, DC 20005\             |                                   |
| Phone: 202-622-8662\              |                                   |
| Fax: 202-622-7754                 |                                   |
+-----------------------------------+-----------------------------------+
| **USCS**\                         | **Bureau of Alcohol, Tobacco &    |
| U.S. Customs Service\             | Firearms**                        |
| 1300 Pennsylvania Avenue, NW\     |                                   |
| Washington, DC 20229\             | Office of Liaison and Public      |
| Phone: 202-927-1350\              | Information\                      |
| Fax: 202-927-1380                 | 650 Massachusetts Avenue, NW\     |
|                                   | Room 8290\                        |
|                                   | Washington, DC 20226\             |
|                                   | Phone: 202-927-7777\              |
|                                   | Fax: 202-927-7862                 |
+-----------------------------------+-----------------------------------+
| **BEP\                            | **FLETC**\                        |
| **Bureau of Engraving & Printing\ | Federal Law Enforcement Training  |
| Fourteenth & C Streets, SW\       | Center\                           |
| Washington, D.C. 20228\           | Glynco, GA 31524\                 |
| Phone: 202-874-2485\              | Phone: 912-267-2100               |
| Fax: 202-874-3177                 |                                   |
+-----------------------------------+-----------------------------------+
| **FINCEN\                         | **FMS\                            |
| **Financial Crimes Enforcement    | **Financial Management Service\   |
| Network\                          | Public Affairs\                   |
| 2070 Chain Bridge Road\           | 401 14th Street, SW\              |
| Suite 200\                        | Washington, DC 20227\             |
| Vienna, Virginia 22182\           | Phone: 202-874-6740               |
| Phone: 703-905-3770               |                                   |
+-----------------------------------+-----------------------------------+
| **IRS\                            | **Mint\                           |
| **Internal Revenue Service\       | **U.S. Mint\                      |
| 1111 Constitution Avenue, NW\     | 801 9th Street, NW\               |
| Washington, DC 20224\             | Washington, DC 20220\             |
| Phone: 800-829-1040               | Phone: 202-874-6450               |
+-----------------------------------+-----------------------------------+

  ----------------------------------- -----------------------------------
  **BPD\                              **USSS\
  **Bureau of the Public Debt\        **U.S. Secret Service\
  999 E Street, NW\                   1100 L Street, NW\
  Washington, D.C. 20239\             Suite 6000\
  Phone: 202-219-3302\                Washington, DC 20005\
  Fax: 202-219-4163                   Phone: 202-406-8000

  **OTS**\                            
  Office of Thrift Supervision\       
  1700 G Street NW\                   
  Washington, D.C. 20552\             
  202-906-6000                        
  ----------------------------------- -----------------------------------

# C.2.1 Scope of Work

The scope of this SOW is to provide Contractor support to The Department
of the Treasury and its bureaus (hereinafter called the Government).
Work covered by this SOW contains a number of tasks that may be ordered
by any bureau. Task orders will be issued depending on the level of
Contractor support required by an individual bureau. Not all bureaus
will require the same level of support.

The A-76 competitive sourcing program requires a standardized,
structured process for determining the most efficient and cost effective
method of performance for recurring commercial activities that should be
operated under contract with a commercial source, in-house using
Government facilities and personnel or through Interservice Support
Agreement (ISSA). A-76 is designed to allow for a fair and equitable
competitive process. The offeror providing the best value solution to
the Government PWS competes with the Government's Most Efficient
Organization (MEO).

This SOW organizes the A-76 study process into seven broad areas:

1.  Competitive Sourcing Program Management Support.

2.  Competitive Sourcing Feasibility/Business Case Analysis Support

3.  Development of the PWS and QASP Support.

4.  Development of the Management Plan Support.

5.  Competitive Sourcing Proposal Evaluation Support.

6.  Competitive Sourcing Independent Review Support.

7.  Post-MEO Performance Review Support.

Before the announcement, the requiring activity(ies) will consider the
scope of the study. Specifically, they will consider functions to be
studied, the specific set of employees who will be affected,
opportunities to fold in similar or related functions on a regional
basis, and whether multiple activities might be consolidated for
treatment in the same study. Consideration of these factors is known as
the "business unit definition," or, "packaging of the study." Study
success and meeting the intent of Circular A-76 often are heavily
affected by these considerations.

# C.2.2 Competitive Sourcing Contractor Support Guidelines 

To mitigate the risk or perception that a conflict of interest exists
for Contractors conducting different aspects of the A-76 process; and to
ensure that all aspects of the study are carried out on a level playing
field, the following guidelines will be adhered to when selecting
Contractors to perform competitive sourcing tasks:

# 

**[Competitive Sourcing Contractor Support Tasks]{.underline}**

1\. Competitive Sourcing Program Management Support

2.  Competitive Sourcing Feasibility/Business Case Analysis

3.  Develop Performance Work Statement (PWS) and Quality Assurance
    Surveillance Plan (QASP) Support

4.  Develop the Management Plan Support

5.  Proposal Evaluation Support

6.  Independent Review Support

7.  Post-MEO Performance Review Support

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**[Competitive Sourcing Contractor Support Guidelines]{.underline}**

1.  [Overarching Premise]{.underline}: A Contractor may be eligible to
    perform under any of the above support tasks, provided that such
    participation does not present any organizational/program conflict
    of interest.

2.  A Contractor performing services under Tasks 1 and/or 2 will not be
    considered for support in Tasks 3 through 7 for any specific
    functional area study.

3.  A Contractor performing services in Tasks 3 through 7 above will be
    limited to performance in only one of these categories to support a
    specific functional area study. For example, a Contractor providing
    PWS and QASP support (Task 3) will not be considered for
    participation in Tasks 4 through 7 for a specific study.

4.  A Contractor may participate in multiple support categories,
    provided that the support is provided on different functional area
    studies. For example, a Contractor may provide PWS support on an
    AWSS study, while also providing MEO support on a MITS study.

5.  Contractor\'s past performance on specific tasks will be considered
    in the evaluation of future task order awards. However, the source
    selection results/outcome of previous comparison studies in which
    the contractor participated will not bias the selection criteria for
    future support efforts.

**NOTE:** On a case by case basis, a Contractor may be considered for
participation in more than one Task for a particular functional area
study (e.g. Tasks 3 {Develop PWS & QASP Support} and Task 4 {Develop the
Management Plan Support}). The Government reserves the right to request
written documentation from the Contractor, providing evidence of
internal firewall procedures, internal control procedures, quality
control plans, etc. This documentation shall demonstrate that the
Contractor has internal mechanisms in place so as to strictly avoid any
conflict of interest or even the appearance of a conflict of interest in
accordance with FAR 3.1 Safeguards and FAR 9.5 Organizational and
Consultant Conflicts of Interest.

# C.3.0 Description of Tasks

The following tasks describe the Government's requirements for complying
with the provisions of the FAIR Act of 1998.

# C.3.1 Task 1: Competitive Sourcing Program Management Support

The Contractor shall provide Management Support in the design and
development of the Government's compliance program for FAIR Act/A-76
initiatives.

# C.3.1.1 Sub-task 1.1: Identify Inherently Governmental Positions

The "Federal Activities Inventory Reform Act of 1998," P.L.105-270 (the
FAIR Act),

requires Federal agencies to prepare and submit to OMB, by June 30 of
each year, inventories of their commercial activities performed by
Federal employees. OMB is required to review each agency's inventory and
consult with the agency regarding its content. Upon completion of this
review and consultation, the agency head must transmit a copy of the
inventory to the Congress and make it available to the public. The FAIR
Act then establishes a two-step administrative challenge and appeals
process under which an interested party may challenge the omission or
the inclusion of a particular activity on the inventory.

The A-76 *Supplemental Handbook* defines an inherently governmental
activity as one that is so intimately related to the exercise of the
public interest as to mandate performance by Federal employees.

Early in the planning process, the Commercial Activities (CA) Program
Manager should determine whether particular positions within an activity
are inherently governmental. Guidance on inherently governmental
functions is provided at FAR 7.5, which implements OFPP Policy Letter
92-1, "Inherently Governmental Functions" (Appendix 5 to the OMB
Circular A-76 Revised Supplemental Handbook). An inventory of all
functional areas is taken annually in accordance with provisions of the
FAIR Act. Although this annual inventory provides a baseline for the
functional area inventory, the CA Program Manager should ensure that the
inventory data are validated before beginning an A-76 study.

The Contractor shall provide support to the Government in complying with
the FAIR Act. The following activities may require Contractor support:

-   Determination of \"inherently Governmental activities\";

-   Compilation of annual inventories;

-   Creation of Congressionally mandated reports;

-   Preparing or researching the defense of challenges regarding an
    omission of a particular activity from, or an inclusion of a
    particular activity on, a list for which a notice of public
    availability has been published under Section 2 of the Act; and,

-   Providing ad hoc services, as required.

# C.3.1.2 Sub-task 1.2: Plan Commercial Activities Study

The purpose of this sub-task is to develop an *Action Plan* for
conducting an A-76 commercial activities study. The plan defines the
scope of the study and the key actions required. The Contractor shall
provide support to the Government as follows:

# C.3.1.2.1 Sub-task 1.2.1: Develop a Communications Plan

Communication with various levels of the organization greatly
facilitates the A-76 study. These communications should include
information on the A-76 study process, the commercial activity under
study, employee rights, union involvement, and periodic updates on the
status of the study.

-   [Develop a Communications Plan]{.underline} - The Contractor shall
    provide support to the Government in developing a Communications
    Plan. The plan is a walk through of the A-76 process highlighting
    responsibility of senior management, key events; and, interface with
    HRO, unions, and the functional organization under study. The plan
    at a minimum shall include:

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-   Employee groups;

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-   Public announcements - both national and local;

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-   Communication with national and local union organizations;

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-   Congressional inquires;

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-   News organizations;

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-   All-hands meetings;

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-   Customers and suppliers of the activity under study;

-   Discussion of alternatives; and,

-   Facilitating meetings.

# 

# C.3.1.2.2 Sub-task 1.2.2: Create a CA Team

The Government will create a CA team to conduct all activities and
functions necessary for successful completion of a CA study, more
commonly called an A-76 study. Each task order will identify the CA Team
members.

Each Treasury bureau will determine the makeup of the CA team based on
the size, scope, and complexity of the function under study. Some CA
teams may require more participants than others when the study has
national, regional or cross-functional implications. Chart 1 is a
suggested CA team organization chart:

![](media/image1.wmf)

**Chart 1**

There is no standard size for a CA team. The CA team composition varies
greatly with the complexity of the function being studied, the resources
available to the CA Program Manager, and the capability of the
individual team members.

Representatives of labor organizations may participate as members of
agency commercial activities (CA) teams responsible for developing the
PWS and the MEO. Participation as full members is permissible as long as
each member complies with all rules and policies applicable to all team
members. This includes executing nondisclosure statements*,* if
required. Additionally, union representation in communication forums,
general interest video teleconferences (VTC), etc., are authorized and
encouraged. Section 2467(b) of Title 10, U.S.C., requires the agency to
consult at least monthly with employees who will be affected during the
development and preparation of the PWS and the management efficiency
study*,* and obtain their views. For employees represented by a labor
organization, consultation is conducted through the representatives of
that labor organization. Pursuant to Part 1, Chapter 1, paragraph G1.a
of Circular A-76 Supplemental Handbook, consistent with any procurement
and conflict of interest requirements, affected parties have the
opportunity to participate in developing supporting documents and
proposals, including in-house and contract cost estimates. Further,
paragraph G1.b provides that "upon issuance, a solicitation used in the
conduct of a cost comparison will be made available to directly affected
Federal employees or their representatives for comment."

Although neither of the provisions described above mandates that labor
organizations representing employees serve as CA team members,
participation on PWS and MEO teams would provide a means of satisfying
the requirements for consultation and participation. It is also noted
that there is nothing contained in the criminal conflict of interest
statutes, the Procurement Integrity Act (41 U.S.C. 423), or the
government-wide Standards of Ethical Conduct for Executive Branch
Employees (5 CFR part 2365) that prohibits agency management from
allowing union representatives to serve as CA team members. In fact,
such participation would likely be viewed as consistent with the spirit
of Executive Order 12871, "Labor Management Partnerships," which
requires agencies to involve employees and their union representatives
as full partners with management representatives to identify problems
and craft solutions to better serve the agency's customers and mission.
The same union member is not normally assigned to both the PWS and MEO
teams, nor should information be shared between these two teams.

Certain actions are performed in Step 1 to facilitate planning for and
timely completion of the study. Educating employees about the A-76
competitive sourcing process and sharing information regarding the study
process and potential outcomes can help ease employee concerns. Union
participation in the VTCs, on the PWS and MEO teams, and in
communications forums delineated in the Communication Plan, is deemed to
satisfy 10 U.S.C 2467(b). This participation also offers the opportunity
to consider employee feedback in the A-76 process. Regardless of
satisfying legal requirements, the CA Program Manager is directly
involved to ensure open communication with employees, their
representatives, affected ISSA providers, and the local community.

[Create a CA Team]{.underline} - The Contractor shall provide support to
Treasury bureau executives and Personnel Offices in forming CA teams
that have the necessary skills to conduct an A-76 study. Many of the
individuals working on the A-76 study will only be needed on a part-time
or *ad hoc* basis. Because of the large number of skills sets needed to
conduct an effective A-76 study, the Contractor shall provide estimates
of the amount of time needed by various skill categories. The CA team
may include individuals or Contractors with the following skills and
abilities:

-   CA Program Manager;

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-   CA Team Leader;

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-   Management analysts with expertise in the functional area under
    study;

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-   Organizational analysis;

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-   Work measurement ;

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-   Strategic HR;

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-   Position classification;

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-   Contract administration;

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-   Cost and price analysis;

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-   Productivity improvement;

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-   Business process reengineering;

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-   Activity modeling;

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-   Functional/economic analysis;

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-   Operations research;

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-   Activity-based costing;

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-   Benchmarking; and,

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-   Data modeling.

# C.3.1.2.3 Sub-task 1.2.3: Define the Scope of the A-76 Study

-   [Define the Scope of the A-76 Study]{.underline} - Following the
    announcement that a particular function will be studied under the CA
    process, the Contractor shall provide support to the CA Program
    Manager, CA Team Leader, and the affected organization\'s senior
    management to discuss all issues surrounding the function to be
    studied. The Contractor shall provide support to the CA Team to
    establish the boundaries of the function or scope of the work under
    study. Where these boundaries are set is crucial to the
    organization\'s ability to perform the work regardless of the
    competitive outcome. In defining the scope of work, boundaries
    should be established in such a way that the product or service
    produced by the activity is adequately maintained. Analysis of the
    function under study shall include:

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-   Identification of the elements of the organization that perform the
    work under study;

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-   Identification of associated groups that interact and support the
    core function;

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-   Consideration of the potential effect this study would have on the
    internal and external support groups to the organization.

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-   ISSA services provided by a host organization or other reimbursable
    activity should be included as part of the scope of work,
    particularly when the service has a major impact on the performance
    of the core functions.

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-   Plan development of the Performance Work Statement (PWS).

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-   Plan development of the Quality Assurance Surveillance Plan (QASP).

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-   Develop data collection and analysis methodology.

-   Develop a schedule of milestones and involvement of key players
    throughout the process.

-   Develop a Transition Plan (TP).

# C.3.1.2.4 Sub-task 1.2.4: Develop a Training Plan

The Contractor shall develop a training plan, provide training
materials, and conduct training sessions for CA team members, employees
in functions under study, union representatives and other interested
parties. These training sessions shall include training on all aspects
of the A-76 process. Training shall include, but is not limited to, the
following topics:

-   The A-76 commercial activities process;

-   The decision process;

-   The PWS and QASP;

-   The Management Plan;

-   The appeals process; and,

-   The transition process.

# C.3.1.2.5 Sub-task 1.2.5: Execute Transition Plan

The Contractor shall support the Government in executing the TP. The CA
team creates the TP during development of the Management Plan, in Task
4, to facilitate an efficient transition upon award of the solicitation.
The TP describes how the current organization will make the changes
necessary to implement the Most Efficient Organization (MEO). The TP
should account for two possible outcomes: the transition to the MEO if
the Government is selected for award, and the transition to contract
performance if the Contractor is selected for award.

# C.3.2 Task 2: Competitive Sourcing Feasibility/Business Case Analysis

The Contractor shall provide support to the Government in conducting
feasibility studies and conducting business case analysis.

# C.3.2.1 Sub-task 2.1: Conduct Competitive Sourcing Feasibility Studies

The Contractor shall provide support to the Government in conducting
feasibility studies of recurring commercial activities to determine
whether acquiring the activities under contract are warranted.
Commercial activity feasibility studies shall include:

-   Baseline FTEs, budgets, and supporting resources associated with the
    function under study.

-   Performance requirements for functions under study.

-   Recommended strategy for competitive sourcing alternatives (method
    of procurement).

-   An analysis related to commercial activities issues.

# 

# C.3.2.2 Sub-task 2.2: Competitive Sourcing Business Case Analysis

The Contractor shall support the Government in developing high-level
business cases to demonstrate return on investment (ROI) or other
benefits related to functions under study.

# C.3.3 Task 3: Develop PWS and QASP Support

The purpose of Task 3 is to develop the Performance Work Statement (PWS)
and the Quality Assurance Surveillance Plan (QASP). The PWS describes
the work requirements, performance measures and standards, and time
frames for performance. It is the basis for the performance-based
service contract solicitation, Contractor proposals, and the Government
in-house organization's Technical Performance Plan (TPP), which is based
on performing the requirements, described in the PWS.

The PWS should be developed so either a Contractor or the Government's
Most Efficient Organization (MEO), depending on the results of the cost
comparison, can perform it. The PWS should not be overly prescriptive
regarding how work is to be performed and should permit use of
appropriate innovations that lead to increased efficiency and improved
levels of quality.

A thorough understanding of organizational mission and a clearly worded
mission statement are essential when creating a performance-based PWS.
The PWS should address the need for variations in workload demand that
could be required for contingency operations that may arise as a part of
the organization's mission. Additionally, identifying any risks involved
with performing a particular function and developing appropriate risk
mitigation strategies to be included in the PWS are important
responsibilities for the CA Program Manager, CA Team Leader, and the CA
Team.

The QASP defines the process by which the Government evaluates the
execution of the PWS, regardless of whether the service provider is a
Contractor or the Government MEO. Although the QASP accompanies the PWS
to the independent review official (IRO) for a cost comparison, it
should not be included as a part of the solicitation or provided to
private sector offerors. In-house, contract, and inter-service support
agreement (ISSA) offerors should develop their offers based on the
requirements of the PWS alone.

The Contractor shall provide support to the CA Team Leader and the CA
team to develop the PWS and QASP. PWS and QASP development includes the
following sub-tasks:

# C.3.3.1 Sub-task 3.1: Conduct Market Research

The Contractor shall provide support to the CA team to gather data and
knowledge about how the function under study is accomplished in private
industry. This process is intended to determine what new techniques,
successful endeavors, and emerging trends exist and which of these
processes or procedures can be included in the PWS and the Management
Plan.

The purpose of the informal market research is to develop a detailed
description of the function under study, including the means and methods
of measuring performance. The objective of this data gathering is to
prepare for the ensuing solicitation. This information can be applied to
developing the performance standards, the PWS itself, the QASP, and the
other aspects of the solicitation. During development of the Management
Plan (Task 4), the information learned from private industry may be
useful in developing new operating procedures to improve the quality and
efficiency with which the commercial activities are performed.

Market research activities include:

-   Conduct discussions with potential offerors and industry experts;

-   Conduct \"Industry input days\" to solicit industry input to improve
    the content and quality of the PWS;

-   Conduct direct telephone and mail solicitation;

-   Advertise in the *Government's Point of Entry (GPE or
    FedBizOpps.gov)*;

-   Research industry newspapers and trade journals;

-   Conduct internet searches; and,

-   Conduct research on information services databases (Gartner,
    Faulkner, etc.).

# C.3.3.2 Sub-task 3.2: Define Present Operations

Developing the PWS begins with gathering data that define present
operations. The Contractor shall provide support to the Government in
developing a PWS for the function under study. Data for this effort
shall include:

-   Current Organization;

-   Organization\'s mission;

-   Current problem areas in the function;

-   Workload;

-   Staffing;

-   Facilities;

-   Equipment;

-   Work measures;

-   Standards; and,

-   Customer base.

# C.3.3.3 Sub-task 3.3: Develop Performance Measures and Standards

The Contractor shall provide support to the Government in developing
performance measures and standards, performance indicators, and quality
levels for the function under study. Sources for developing these
measures and standards at a minimum should include:

-   Industry \"best\" practices;

-   Government \"best\" practices;

-   Historical data;

-   Productivity or performance enhancement projects;

-   Business process reengineering projects;

-   Business case analysis;

-   Industry standards;

-   Customer surveys; and,

-   Management input.

# C.3.3.4 Sub-task 3.4: Develop the Performance Work Statement (PWS)

When all data has been gathered and analyzed, the Contractor shall
provide support to the CA team to prepare the PWS, including performance
measures. The PWS shall provide general information on the scope of
work, where contracting products/services will be provided or located,
and the performance period. The bulk of the PWS shall detail specific
responsibilities of the service provider and of the CA, and shall
include a list of technical attachments detailing the
Government-furnished facilities, equipment (GFE), materials, and
supplies.

# C.3.3.5 Sub-task 3.5: Develop Quality Assurance Surveillance Plan (QASP)

The Contractor shall provide support to the CA team to develop a QASP
for the function under study. The QASP shall describe the procedures to
be used by the Government to ensure that the service provider---whether
Government or Contractor---is meeting the minimum requirements of the
PWS.

Service providers are responsible for building quality control into
their processes. The QASP includes the method of inspection the
Government will use, reports required, and Government resources to be
employed.

When determining the appropriate level of quality surveillance, the CA
Team Leader must consider the level of risk acceptable given the
relationship of the commercial activity to the organization's mission.

# C.3.3.6 Sub-task 3.6: Obtain Higher Level Review of PWS and QASP

During this step, a Source Selection Advisory Council (SSAC) or other
Government Advisory Board may provide review of the draft Quality
Assurance Surveillance Plan (QASP) and the draft Performance Work
Statement (PWS). Although this higher-level review takes place outside
the immediate organization conducting the A-76 study, the Contractor
shall support the CA Program Manager in facilitating this review by
coordinating with the SSAC or other Government Advisory Board while the
PWS and QASP are being developed and reviewed internally. The goal of
this coordination is to keep the higher-level authority informed of the
status of the PWS and QASP development. It also serves to convey the
higher-level authority's viewpoints, via the CA Program Manager and
Commercial Activity (CA) team.

# C.3.4 Task 4: Develop the Management Plan Support

The purpose of Task 4 is to develop a Management Plan comprising the
Most Efficient Organization (MEO) document, an In-House Cost Estimate
(IHCE), a Technical Performance Plan (TPP), and a Transition Plan (TP).
This Management Plan, the in-house organization's "bid," is compared to
the best-value offer submitted by private industry in response to the
solicitation.

Developing the Management Plan is an iterative process. The goal in
creating the MEO document is to develop the best possible organization
capable of performing the work defined in the Performance Work Statement
(PWS). The IHCE constitutes the Government's cost estimate based on the
MEO's performance of the PWS. The TPP is the Government's proposal for
meeting the performance requirements of the PWS and must be based on the
MEO. The TP describes the organization's plan for moving from the
current organizational structure to the MEO or Contractor performance,
while maintaining or improving required performance levels. Because
these tasks are interrelated and developed concurrently, they can begin
at any time in the process of developing the Management Plan.

The Management Plan must support the performance requirements defined in
the PWS developed in Task 3. In developing the Management Plan, the
Commercial Activities (CA) study can consider any previously conducted
business case analyses, business process reengineering, or
organizational analyses efforts. Completion of the Management Plan
concludes the primary involvement of the CA team.

The Contractor shall provide support to the Government to develop a
Management Plan for the function under study. Sub-tasks associated with
the Management Plan include:

-   Gather and analyze data;

-   Conduct data gathering interviews;

-   Estimate workload requirements;

-   Analyze current organizational structure and processes;

-   Develop the MEO;

-   Conduct mock reduction in force;

-   Develop the in-house cost estimate;

-   Develop the technical performance plan;

-   Develop the transition plan; and,

-   Develop MEO quality control procedures.

# C.3.4.1 Sub-task 4.1: Gather and Analyze Data

Much of the information required to develop the Management Plan is the
same as that collected during the development of the PWS and QASP. They
do, however, differ in level of detail.

The Contractor shall provide support to the CA Team in the development
of an interview guide to assist in defining the work of the function
under study.

Before the data-gathering stage can begin, the CA team must meet and
agree on an interview guide format to help ensure interviewing
consistency. The CA team should establish a timeline for collecting
workload data that includes time to conduct interviews, gather available
data, and analyze workload data. Given that workload data may not always
be readily available or may not be available in the required format, the
CA team should agree to an approach for estimating workload data when
necessary. The method for estimating data should be described, and an
audit trail should be provided in the Management Plan.

# C.3.4.2 Sub-task 4.2: Conduct Data Gathering Interviews

Interviewing employees in an activity that is the subject of the CA
study can be an effective data-gathering technique. During interviews,
the CA team should identify all tasks performed by employees, including
any non-routine tasks, to ensure that all work is included in the
workload analysis. The CA team should also identify any additional
workload requirements that the activity is planning to undertake. As
with the PWS, the Management Plan must comply with requirements imposed
by statute or regulation in the performance of the function under study.

**C.3.4.3 Sub-task 4.3: Estimate Workload Requirements**

The Contractor shall provide support to the CA team to estimate workload
requirements. Workload estimating techniques that can be used include
analysis of historical data, work sampling, technical estimates, and
other forecasting techniques. Reviewing historical data begins with
determining the data required and identifying appropriate sources. The
CA team should obtain copies of previous reports or studies specifying
the volume of work, resource requirements, productivity rates,
performance requirements and standards, or performance times. This
information can be used to define work requirements over a period of
time.

In performing work sampling, the laws of probability can be applied to
forecast the amount of time spent on various tasks. Using this
technique, the CA team would make random observations of the work
conducted over a period of time, applying random sampling to reduce the
level of bias that can be introduced through sampling observations.
These observations of current work can be used to determine the
proportion of time dedicated to productive versus nonproductive tasks.

# C.3.4.4 Sub-task 4.4: Analyze Current Organization

The Contractor shall provide support to the CA team to document the
organization, as it exists at the start of the study. This profile
should include a description of the organizational structure (both
formal and informal), the mission and functions, staffing plans,
facilities, and equipment. In developing the staffing plan for the
existing organization, the CA team must identify all staff assigned to
the function, including full-time and part-time Government employees,
and any Contractor employees currently participating in the function
under study.

# C.3.4.5 Sub-task 4.5: Develop the Most Efficient Organization (MEO)

In developing the Management Plan, the CA team must describe the optimum
organization, known as the MEO, to perform the work specified in the
PWS. The Contractor shall provide support to the CA team in developing
an MEO. Every effort shall be made to create an MEO that includes the
following efficiencies:

-   Improvements in operations;

-   Reductions in staffing;

-   Identification of impact on support areas;

-   Improvements in facility layout or equipment utilization; and,

-   Other ideas designed to improve performance.

Many techniques are available to the CA team in developing the MEO. The
CA team should focus on innovative and creative approaches to performing
the function;

however, the MEO must be an organization that can be implemented by the
Government. In developing the MEO, the Contractor shall provide support
to the CA team to incorporate the latest developments in business
management including:

-   Business process reengineering principles;

-   Technology utilization;

-   Industrial engineering where applicable;

-   Activity-based costing;

-   Workflow diagrams;

-   Business case analysis; and,

-   Organizational analysis.

Because of the time constraints imposed by the A-76 timeline, the CA
team can use some of these techniques in conjunction with simulation
models. Creating a simulation of the MEO may help the CA team visualize
the impact of changes associated with implementation of the MEO. The
following are examples of information that can be used to develop the
MEO:

-   Organizational chart---new organizational structure required to
    support the MEO

-   New work breakdown structure

-   New workflow design

-   New position descriptions and grade structures

-   New performance measures

-   New facilities layout and productivity-enhancing equipment

-   Recommended revisions or amendments to existing contracts

-   Estimates of materials and supplies needed during the performance
    period

-   Technology or information technology (applications that could
    improve organizational performance if they can be funded and
    implemented).

# C.3.4.6 Sub-task 4.6: Conduct Mock Reduction-in-Force (RIF)

After the MEO is developed, the Human Resources Officer (HRO) can
conduct a mock reduction in force (RIF). The purpose of the mock RIF is
to help develop the TP under both the MEO and Contractor scenarios, as
well as to provide information for the IHCE.

The mock RIF assists in estimating the costs of relocation and training
for affected personnel and minimizing adverse effects on employees, by
planning for how to place or assist them. If the Government loses the
bid, the mock RIF information will be useful in planning for the
reductions in the entire in-house organization. If the Government wins
the bid and implements the MEO, the information can be used in
implementing the reductions of the affected personnel.

# C.3.4.7 Sub-task 4.7: Develop the In-House Cost Estimate (IHCE)

The Contractor shall provide support to the CA team to develop the IHCE
portion of the Management Plan, which details the cost of the MEO's
performance of the requirements in the PWS. The IHCE is prepared using
the following factors:

-   Personnel costs

-   Material and supply costs

-   Other specifically attributable costs

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-   Depreciation

-   Cost of capital

-   Rent

-   Maintenance and repair

-   Utilities

-   Insurance

-   Travel

-   MEO subcontracts

-   Other costs

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-   Overhead costs

-   Additional costs (any other costs not included elsewhere).

The A-76 *Supplemental Handbook* states that an activity cannot be
converted to contract based on a cost comparison unless a minimum cost
differential is met. The minimum cost differential is the lesser of 10
percent of in-house personnel related costs or \$10 million over the
period of performance. Some other costs such as one-time conversion
costs and contract administration costs can be calculated and determined
as part of the IHCE.

# C.3.4.8 Sub-task 4.8: Develop the Technical Performance Plan

The Contractor shall provide support to the CA team to develop the
Technical Performance Plan (TPP). The TPP describes how the MEO will
perform the work requirements of the PWS.

The TPP should describe the Government\'s technical and management
approach to performing the requirements of the PWS, specifying how the
performance requirements will be met, measures of performance, staffing
by functional area, staffing utilization, and facilities utilization.

It also must describe how changes in the workload will be addressed in
the MEO.

# C.3.4.9 Sub-task 4.9: Develop the Transition Plan

The Contractor shall provide support to the CA team to develop the
Transition Plan (TP). The TP describes how the current organization will
make the changes necessary to implement the MEO.

The TP should account for two possible outcomes: the transition to the
MEO if the Government is selected for award and the transition to
contract performance if the Contractor is selected for award.

The IRS understands the sensitive nature of the A-76 process and the
potential impact on its employees if the Government MEO is not selected
for award. Every effort will be made to provide employees with a range
of options that help IRS employees negotiate the transition process.
Strategic Human Resources will work with employees on an individual
basis to assist them in determining the best course of action based on
the employee's individual needs. The ranges of options that may be
available to affected employees are:

-   Right of first refusal for jobs with the selected Contractor;

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-   Voluntary Early Retirement Authority - commonly referred to as
    \"Early Out\". Note that this authority is granted by the Office of
    Personnel Management on a fiscal year basis based on the
    justification of need for the authority.

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-   Voluntary Separation Incentive Payments \-- commonly referred to as
    \"Buyouts\". Note that the IRS only has this authority through RRA98
    through January 1, 2003. Previously this authority was granted
    government-wide.

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-   Vacancies within the commuting area would be offered, for which the
    employee qualified.

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-   Career Counseling. In the past this has included career counseling
    within the organization to have employees consider positions within
    the organization. A personnel specialist or career counselor would
    review the employee's qualifications and indicate what training
    would be necessary to have them qualify for additional positions. In
    most cases, the Service has offered that training through various
    means. We have also had outplacement firms under contract to provide
    resume writing, interviewing skills, financial planning, etc. to
    employees who were in positions that were jeopardized.

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-   Offered grade and/or pay retention, in accordance with applicable
    laws and regulations, to those employees who applied and were
    selected for a voluntary change to lower grade; and,

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-   Moving expenses to those impacted employees who applied and were
    selected for a position outside his/her normal commuting area.

# C.3.5 Task 5: Proposal Evaluation Support

The Contractor shall support the Government in conducting technical
evaluations of the MEO and Contractor technical proposals submitted in
response to the PWS.

# C.3.6 Task 6: Independent Review Support

The Contractor shall provide Independent Verification and Validation
(IV&V) of the Government's FAIR Act/A-76 program, to include process,
procedures, documents and compliance issues.

To ensure that the PWS and Management Plan meets the requirements of
Circular A-76, fairly presents the work to be done, and adopts the most
appropriate performance metrics; these documents will be reviewed by
Government and Contractor personnel. The QASP will be reviewed at the
same time for compliance with Circular A-76 and use of proven, sensible,
quality management methods.

# C.3.6.1 Sub-task 6.1: Review PWS and QASP

The Contractor shall perform a review of the Performance Work Statement
(PWS) and Quality Assurance Surveillance Plan (QASP). This review
ensures that all the important issues raised during Tasks 3 and 4 have
been adequately reflected in the PWS and QASP. These issues may include
determining whether business-related matters have been adequately
addressed, whether boundaries of the commercial activity (CA) have been
adequately defined, whether the PWS is performance based and focused on
desired outcomes rather than process based, and whether contingency
requirements are adequately addressed.

During this step, effective communication, and coordination between the
key and advisory players ensures that all these important issues are
adequately dealt with in the PWS and QASP. Additionally, careful
coordination within the organization facilitates the higher-level
approval of the PWS and QASP.

# C.3.6.2 Sub-task 6.2: Review Management Plan

The Contractor shall conduct an independent review of the Government's
Management Plan. The Contractor shall determine if the data contained in
the Management Plan reasonably establishes the Government's ability to
perform the PWS *requirements* within the resources provided by the MEO.
The Contractor shall determine if all costs entered on the CCF are fully
justified and calculated in accordance with the procedures described in
Part II of the A-76 *Supplemental Handbook*. Review of the Management
Plan shall include the MEO, IHCE, TPP, and TP, along with all supporting
documentation.

# 

# C.3.6.3 Sub-task 6.3: Review FAIR Act/A-76 Process

The Contractor shall perform an independent review of the Government\'s
A-76 process

contained in this SOW for compliance with OMB Circular A-76. A work
request will be issued that defines the scope of the independent review
requested by the Government.

# C.3.7 Task 7: Post-MEO Performance Review Support

When the MEO, as a result of a cost comparison performs services,
quality control and quality assurance are processes and procedures used
to monitor the quality of the work performed by the MEO throughout the
performance period and to prepare for the Post-MEO Performance Review.
The MEO develops and implements a quality control process to ensure that
quality standards are met. Government Quality Assurance Evaluators (QAE)
develop quality assurance procedures to ensure that the MEO is following
its established quality control process and meeting the requirements of
the QASP.

The Contractor shall conduct a formal review and inspection of the MEO
at the end of the first full year of performance. The review shall
confirm that the MEO has been implemented in accordance with the TP,
establishes the MEO's ability to perform services of the PWS, and
confirms that actual costs are within the estimates contained in the
in-house cost estimate. Adjustments may be made for formal mission or
scope of work changes. The A-76 *Supplemental Handbook* states that
Post-MEO Performance Reviews must be conducted on not less than 20
percent of the functions performed by the Government as a result of the
cost comparison.

If the Post-MEO Performance Review determines that the Government has
failed to implement the MEO as provided in the TP, or that the MEO is
not meeting the minimum performance standards, the contracting officer
will award a contract to the next lowest offeror who participated in the
cost comparison. If award to the best-value contractor is not feasible,
the contracting officer will immediately resolicit to conduct a revised
and updated cost comparison.